Search - consideration

Results 3571 - 3580 of 8030 for consideration

6 March 1984 Income Tax Severed Letter RRRR89 - Non-resident withholding tax—Canada-Italy treaty

It would appear to us that subparagraph 212(1)(d)(i) of the Act is applicable in respect of the XXX Article XII of the Canada-Italy Income Tax Convention (the Convention) defines “royalties” as payments of any kind received as consideration for the use of, or the right to use, any copyright..., patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience (emphasis added). ...

7 August 1990 Income Tax Severed Letter - Review of draft NR4B guide and forms

We have reviewed the draft documents and offer the following comments for your consideration. ...

29 December 1988 Income Tax Severed Letter RRRR155 - Non-profit corporation passing tax deductions to taxable entities

Since this issue is relevant for purposes of an advance income tax ruling which we now have under consideration, we would appreciate an early response. ...

7 September 1982 Income Tax Severed Letter RRRR64 - Foreign affiliates

Paragraph 95(2)(b)(i) of the Income Tax Act provides: "(b) the income of a controlled foreign affiliate of a taxpayer from services or an undertaking to provide services shall be deemed to be income from a business other than an active business if (i) the amount paid or payable in consideration therefor is deductible in computing the income from a business carried on in Canada by any person in relation to which the affiliate is a controlled foreign affiliate or by a person related to that person, or" (underlining added). ...

7 September 1990 Income Tax Severed Letter - Privileges and immunities for international organizations

We do not have sufficient information concerning the staff retirement funds or the circumstances under consideration by you in connection therewith to comment definitively as to the proper tax treatment thereof. ...

7 September 1990 Income Tax Severed Letter - Definition of “disposition” for the purposes of paragraph 13(21)(c) of the Income Tax Act

The administrative policy of Revenue Canada concerning the disposition of property in the absence of any consideration is found in Interpretation Bulletin IT-460. ...

7 August 1990 Income Tax Severed Letter - Application of subsection 12.2(9) of the Income Tax Act to a hypothetical situation

In our telephone conversation of July 31, 1990 you stated, as a point of clarification, that one of the changes under consideration was a change from an ordinary life plan to an adjustable single premium life plan. ...

7 August 1990 Income Tax Severed Letter - Gifts

XXX Our Comments A gift is a voluntary and gratuitous transfer of real or personal property without consideration. ...

19 July 1980 Income Tax Severed Letter RRR11 - Residency status of members of the Canadian Forces on leave without pay and tax treatment of certain types of income

XXX residential status must then be determined according to the usual considerations as set out in Interpretation Bulletin IT-221. ...

15 May 1990 Income Tax Severed Letter RRRR349 - Application of subsection 191(4) to a particular situation

The consideration received by the parent might include a preferred share retractable at the option of the parent for an amount equal to the fair market value ("FMV") of the Opco shares transferred. ...

You are here