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Results 3751 - 3760 of 8027 for consideration
Miscellaneous severed letter
22 January 1990 Income Tax Severed Letter ACC8916 - Canada-Finland Income Tax Convention - Social Security Pensions from Finland
It is our understanding that certain benefits (or portions thereof) paid under a national social security scheme may be considered pensions received in consideration of past services, particularly where the amount of the benefit is effected by premiums paid as a result of services rendered. ...
Miscellaneous severed letter
13 April 1988 Income Tax Severed Letter 5-5726 - [880413]
A as consideration therefor (in this case $1) and it appears that interest at the rate prescribed by regulation will not be charged to Mrs. ...
Miscellaneous severed letter
27 May 1988 Income Tax Severed Letter 5-5976 - [June 2, 1987 Notice of Ways and Means Motion on Interest Deductibility ("Motion")]
In consideration for the transferred assets Company D issues shares having a fair market value of $700,000 and stated capital of $700,000 to Company C. ...
Miscellaneous severed letter
15 May 1990 Income Tax Severed Letter AC59342 - Estate Freeze Arrangement and Buy-sell Agreement
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. ...
Miscellaneous severed letter
21 March 1990 Income Tax Severed Letter AC74664 - Pension Payments
Perhaps you could ask 19(1) to provide us with all relevant information in such cases for our consideration. ...
Miscellaneous severed letter
26 April 1990 Income Tax Severed Letter ACC9165 - Audit Review
" Our Comments It is our view that section 7 of the Act is not applicable in this situation inasmuch as the employee neither acquired the shares in question nor disposed of his rights for valuable consideration. ...
Miscellaneous severed letter
2 April 1990 Income Tax Severed Letter AC00350 - Tax on Large Corporations - Resource Industry
Meeting with Finance In response to numerous queries received from Revenue Canada concerning the proposed Part 1.3 tax; Finance agreed to attend a meeting with us to discuss their intent and policy considerations inherent in the drafting of the Part 1.3 legislation. ...
Miscellaneous severed letter
28 November 1989 Income Tax Severed Letter AC00292 - Canadian Exploration Expenses - Meaning of "Agreement in Writing"
28 November 1989 Income Tax Severed Letter AC00292- Canadian Exploration Expenses- Meaning of "Agreement in Writing" NOV 28 1989 Rulings Directorate Resource Industries Section Carole Gouin-Toussaint Frank Gillman Director 0-0292 Paragraph 66(15)(d.1) of the Income Tax Act "Agreement in Writing" Background We received a ruling request which proposed the following: 24(1)24(1) The Law Subsection 66(12.6) permits a corporation that has undertaken pursuant to an agreement in writing ("Agreement") to incur CEE, to issue flow-through shares (all in accordance with specific conditions), to renounce such CEE to a person who has given consideration for such flow-through shares, provided amongst other things, that the corporation incurs the CEE to be renounced, between the day the Agreement was entered into and the 24th month after the end of the month that included that day. ...
Miscellaneous severed letter
25 August 1986 Income Tax Severed Letter 5-1669 - [860825]
We are, however, prepared to offer the following general comments for your consideration assuming the following situation: 1. ...
Miscellaneous severed letter
21 November 1990 Income Tax Severed Letter
Our Comments The Courts have described interest as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another". ...