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Results 3861 - 3870 of 8029 for consideration
Technical Interpretation - External

26 January 1996 External T.I. 9528085 - 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

19 March 1996 External T.I. 9531185 - COMMUTED VALUE OF U.S. DEFERRED ANNUITY TO CDN.RESIDENT

A gift is defined as "A voluntary transfer of property without valuable consideration." ... INCOME TAX CONVENTION (1980) In consideration of the fact that the transaction concerns a payment arising in the United States (U.S.) and made to a resident of Canada, reference will have to be made to the provisions of the Canada-U.S. ...
Technical Interpretation - External

25 March 2003 External T.I. 2003-0005165 - CONSERVATION EASEMENTS AND GIFTING

ACO will grant the Easement to BCO pursuant to a conservation easement agreement and will retain the right to reacquire the Easement for nominal consideration. ... Immediately after the sale of the Land is closed, BCO will transfer the Easement to ACO for nominal consideration. ...
Technical Interpretation - External

3 June 2003 External T.I. 2003-0015675 - LUMP-SUM PREPAYMENT OF AUTO LEASE

by an employee earning commission income or earning salary income; Employer/ Self-employed individual A substantial lease payment made at the beginning of the lease, resulting in lower monthly payments, represents consideration for services to be rendered after the end of the year such that subparagraph 18(9)(a)(i) of the Act would apply to limit the deductibility of the outlay or expense. ... Employer/ Self-employed individual A substantial lease payment made at the beginning of the lease resulting in lower monthly payments represents consideration for services to be rendered after the end of the year such that subparagraph 18(9)(a)(i) of the Act would apply to limit the deductibility of the outlay or expense. ...
Technical Interpretation - Internal

6 June 2003 Internal T.I. 2003-0183437 - Distributions from non-res trust

On XXXXXXXXXX subscribed for XXXXXXXXXX preferred shares (the "Preferred Shares") of the Corporation, providing consideration in the form of investments. ... On XXXXXXXXXX sold the Preferred Shares to the Trust for consideration consisting of a loan (the "Loan") in the amount of $XXXXXXXXXX evidenced by a non-interest-bearing promissory note. 7. ...
Technical Interpretation - External

19 April 2004 External T.I. 2004-0056871E5 - PHSP and Health and Welfare Trust

A plan in the nature of insurance, in this respect, must contain the following basic elements: (a) an undertaking by one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ... In our view, a plan that consists of a contract between a sole proprietor with no full-time employees, and a trustee as an administrator, under which the administrator agrees to reimburse the proprietor, his spouse and members of his household for actual medical and hospital expenses, and receives as consideration an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP, since it does not contain the necessary elements of insurance. ...
Technical Interpretation - Internal

1 June 2004 Internal T.I. 2004-0074161I7 - Hong Kong pension plan

Generally, a plan will be considered a superannuation or pension fund 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 and the contributions are used to provide an annuity or other periodical payment on or after the employee's retirement in consideration for his or her employment services. ...
Technical Interpretation - External

15 September 2004 External T.I. 2004-0071731E5 - PHSP-General Information

Therefore, where the plan represents (i) an undertaking by one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain, it will be considered to be in the nature of insurance. ... Therefore, with respect to your first statement, while section 20.01 sets out the maximum deduction permitted to an individual carrying on business through a proprietorship or partnership in respect of a premium, contribution or other consideration paid under a PHSP, the definition and requirements of a PHSP are actually found in the subsection 248(1) definition. ...
Ruling

2004 Ruling 2004-0096101R3 - Lump-Sum Payment In Lieu of PHSP Plan

"Payment" means the single, lump-sum amount that the Company will pay to each Retiree as consideration for the termination of the Retiree's rights to continue to receive Health Care Benefits under the Plan. ... Pursuant to the Agreement, in consideration for the Retiree granting a full, final and complete waiver, release and discharge to the Company of any and all claims, indemnities, damages, and rights of action that the Retiree has or may pretend to have under the Plan, the Company agrees to make the Payment to the Retiree equal to the present value of the estimated Health Care Benefits foregone as a consequence of the termination of the Plan. ...
Ruling

2000 Ruling 2000-0022943 - shares of credit union

XXXXXXXXXX has issued XXXXXXXXXX common shares to XXXXXXXXXX for total consideration of $XXXXXXXXXX. ... Provided that a shareholder of XXXXXXXXXX: (i) holds his or her membership shares of XXXXXXXXXX (the "Designated Shares") as capital property; (ii) deals at arm's length with XXXXXXXXXX immediately before the XXXXXXXXXX described in XXXXXXXXXX; (iii) does not include any portion of the gain or loss otherwise determined, from the disposition of the Designated Shares in computing his or her income for the taxation year in which the exchange takes place; (iv) does not file an election under subsection 85(1) or 85(2) with respect to the Designated Shares; and (v) does not receive any consideration other than the shares of XXXXXXXXXX in exchange for the Designated Shares; and further provided that, immediately after the exchange, (vi) no such holder or any person or persons with whom he or she does not deal at arm's length, and no such holder together with any person or persons with whom he or she does not deal at arm's length, will (a) control XXXXXXXXXX directly or indirectly in any manner whatever, or (b) will beneficially own shares of XXXXXXXXXX having a fair market value of more than 50% of the fair market value of all of the issued and outstanding shares of the capital stock of XXXXXXXXXX then, pursuant to paragraph 85.1(1)(a), such shareholder will be deemed (A) to have disposed of the Designated Shares for proceeds of disposition equal to the adjusted cost base to him or her thereof immediately before the Exchange, and (B) to have acquired the shares of XXXXXXXXXX at a cost equal to him or her equal to the adjusted cost base to him or her of the Designated Shares held by him or her immediately before the Exchange. ...

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