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Miscellaneous severed letter

23 December 1993 Income Tax Severed Letter 9336665 - Irrevocable Charitable Remainder Trust

For the purposes of these provisions, a gift is a voluntary transfer of real or personal property without valuable consideration. ... The general approach is to value the various interests taking into consideration the fair market value of the property itself, the current interest rates, the life expectancy of any life tenants, or current term certain tables, and any other factors relevant to the specific case. ...
Technical Interpretation - External

24 April 1995 External T.I. 9427715 - SECURITIES LENDING

Usually, the borrower pays the lender a fee ("lending fee") in consideration for entering into the arrangement. ... Where the consideration given by the borrower for the shares consists of an obligation to return the shares that obligation would have a value equal to the fair market value of the shares transferred at the time the shares are acquired. ...
Technical Interpretation - External

11 April 1995 External T.I. 9503645 - DEFERRED SALARY LEAVE PLAN

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

5 June 1995 External T.I. 9505815 - DEFERRED SALARY LEAVE PLAN 6801(A)

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

8 June 1995 External T.I. 9507415 - CONDITIONS RE DEF SAL LEAVE PLAN

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

4 July 1995 External T.I. 9511065 - DSLP

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Conference

21 September 1995 CTF Roundtable Q. 1, 9517906 - TRANSFER OF DEBT BY NR (MEANING OF "IN LIEU OF")

However, where the non-resident has transferred or assigned that obligation to a resident of Canada and the purchaser has made a payment to the non-resident as consideration for that obligation and the right to receive an interest payment in respect of that obligation, the portion of that payment that relates to the right to receive the interest payment would be considered an "amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to the non-resident person as, on account or in lieu of payment of, or in satisfaction of, interest". ... In the Hall case, it was concluded that the consideration received by a taxpayer on the sale of matured bond coupons to a third party constituted "amounts received.....in lieu of payment of....interest" in section 6(1)(b) of the pre-72 Act. ...
Technical Interpretation - Internal

13 September 1995 Internal T.I. 9520497 - MOVING EXPENSES

A second consideration is that, under subsection 62(1), a taxpayer who moved to find a new employment position, is only entitled to deduct moving expenses in the "taxation year in which the taxpayer moved from the old residence to the new residence or for the immediately following year". ... The last consideration concerns whether the selling costs ($XXXXXXXXXX) in respect of his residence sold in September of 1991 are deductible. ...
Technical Interpretation - Internal

28 September 1995 Internal T.I. 9509847 - COMPUTER SOFTWARE

ECP This is in reply to your memorandum of April 6, 1995 wherein you submitted a fact situation together with a copy of a computer software agreement between the seller, XXXXXXXXXX, the purchaser and taxpayer under consideration. ... In our view, in the absence of some portion of the $XXXXXXXXXX being attributed to consideration paid the vendor for the options, per se, that entitle XXXXXXXXXX to acquire additional properties (the DBSO and Resale Option), within specified time frames at a guaranteed price, the $XXXXXXXXXX would properly constitute class 12 as the cost of the right to use computer software. ...
Technical Interpretation - External

8 December 1995 External T.I. 9415515 - PAID-UP CAPITAL REDUCTIONS- DELAWARE CORPORATIONS

On incorporation, FA1 issued common shares to Canco for a consideration of $100. ... However no additional shares were received by Canco as consideration. ...

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