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Results 3811 - 3820 of 8029 for consideration
Technical Interpretation - External
27 April 1998 External T.I. E9800145 - non-competion agreements, client lists
In our view, the payment so received by the shareholder would be consideration for his or her right to compete. ... Moreover, this case is currently under appeal Finally, we wish to stress to you that under section 68 of the Act the parties must make a reasonable allocation of the consideration among the assets sold. ...
Technical Interpretation - External
28 October 1998 External T.I. E9825685 - EXPENSES "INCURRED" FOR PREAMBLE TO 66(12.6)
In addition, the definition of flow-through share indicates the corporation must incur qualifying expenses in an amount "not less than" the relevant consideration. ... X pays $100 as sole consideration for the issuance by Corporation A of a flow-through share;- not enter into any other such “agreement in writing”;- incur $125 of “Canadian exploration expense” (“CEE”; within the meaning assigned that term in subsection 66.1(1) of the Act) during the 24 month period commencing February 1, 1999 (being $25 from its own resources and $100 from the above issuance of flow-through shares);- claim $25 of METC but have no other “assistance” [within the meaning assigned that term in subsection 66(15) of the Act] for the purposes of paragraph 66(12.6)(a) of the Act with respect to the $125 of CEE. ...
Miscellaneous severed letter
9 March 1999 Income Tax Severed Letter e9829795.txt - MORTGAGES HELD IN AN RRSP
However, in the circumstances, we have forwarded your letter and our comments to our Registered Plans Division for their consideration. ... A trustee's failure to do so could lead to a consideration by the Department that the plan was not being used in a manner consistent with the provisions of the Act as noted above. ...
Technical Interpretation - External
19 February 1997 External T.I. 9637525 - INDIAN BAND - INCOME RIGHTS TRANSFERRED TO A TRUST
Furthermore, the band transferred its rights to receive revenue to the trust without consideration. ... The establishment of the Trust was not at all motivated by tax considerations. ...
Ruling
30 November 1996 Ruling 9700373 - INTEREST DEDUCTION
The consideration which XXXXXXXXXX will receive from XXXXXXXXXX will be redeemable retractable Preferred Shares of XXXXXXXXXX having a redemption amount equal to the fair market value of the transferred XXXXXXXXXX shares and having an aggregate paid-up capital equal to the stated capital of the transferred XXXXXXXXXX shares. ... Security for the loans by XXXXXXXXXX will be their principal residence personal guarantees and a specific pledge of their shares of XXXXXXXXXX. 11.XXXXXXXXXX will sell their shares of XXXXXXXXXX to XXXXXXXXXX for aggregate consideration of $XXXXXXXXXX allocated as follows: XXXXXXXXXX The share sale agreement will require XXXXXXXXXX to make a payment of $XXXXXXXXXX to XXXXXXXXXX on closing. ...
Ruling
30 November 1996 Ruling 9702203 - WITHHOLDING PART XIII
Under theAmalgamation, all holders of outstanding Subordinate Voting Shares XXXXXXXXXX will receive for such Subordinate Voting Shares a consideration in the form of preferred shares of the amalgamated corporation. ... Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Technical Interpretation - External
11 June 1997 External T.I. 9641425 - UK PERSONAL PENSION SCHEMES
In our opinion, this will only occur where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee or in some cases, where amounts have been contributed by a government. ... An annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services. ...
Technical Interpretation - Internal
10 June 1997 Internal T.I. 9635106 - INDIAN - CONSULTING BUSINESS
This Indian's business income should be pro-rata exempt taking into consideration primarily the location at which he performs his services and also the location of his customers. ... In summary, this Indian's business income should be pro-rata exempt taking into consideration primarily the location at which he performs his services and also the location of his customers. ...
Ruling
30 November 1995 Ruling 9637623 - AMALGAMATION OF DISTRIBUTING CORP
The stated capital of the shares of XXXXXXXXXX II, immediately after the issue of such shares on the amalgamation, will not exceed the aggregate of the paid-up capital of the shares of the predecessor corporations immediately before the merger (excluding the paid-up capital in respect of shares held by any other predecessor corporation). 8.XXXXXXXXXX will file articles of amendment pursuant to the XXXXXXXXXX to create a class of preferred shares that are non-voting, redeemable and retractable for an amount equal to the fair market value of the consideration received on their issuance, having a right to non-cumulative dividends at a rate not to exceed XXXXXXXXXX% per annum on the amount for which the shares are issued, with a par value of $XXXXXXXXXX per share and which will be subject to a price adjustment clause with respect to their redemption and retraction amount (the "Class XXXXXXXXXX preferred shares"). 9.XXXXXXXXXX will redeem and cancel its Class XXXXXXXXXX preferred shares and Class XXXXXXXXXX preferred shares held by XXXXXXXXXX which will result in a deemed dividend that XXXXXXXXXX will elect, pursuant to subsection 83(2), to have been paid from its capital dividend account. XXXXXXXXXX will issue to XXXXXXXXXX as consideration for the redemption of its Class XXXXXXXXXX preferred shares and Class XXXXXXXXXX preferred shares a non-interest-bearing demand promissory note having a principal amount equal to the redemption amount of the preferred shares redeemed. 10.Each of XXXXXXXXXX will exchange all of the XXXXXXXXXX Class XXXXXXXXXX common shares held by them for Class XXXXXXXXXX preferred shares of XXXXXXXXXX with a fair market value equal to the fair market value of the Class XXXXXXXXXX common shares immediately before the exchange pursuant to the provisions of subsection 51(1). ...
Technical Interpretation - Internal
3 June 1997 Internal T.I. 9703437 - payment made by trust-exchanging cheques beneficiary
The deceased received no consideration for this transfer, thereby constituting a gift of the policy within the provisions of the Estate Tax Act... ... As noted above, when determining whether or not to accept that payment of an amount has been made, consideration must be given to: i) whether the payer's cheque would have been honoured by its financial institution where there were insufficient funds available in its account to cover the amount of the cheque, and ii) whether the transactions between the parties are legally effective. ...