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Results 461 - 470 of 8027 for consideration
Miscellaneous severed letter

18 April 1990 Income Tax Severed Letter ACC9143 - Request for Remission of 1983 Tax

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of your case. ...
Miscellaneous severed letter

13 February 1989 Income Tax Severed Letter 7-3316 - [Foreign Exchange—Capital Gain v. Income]

In particular you have enquired about the accounting of foreign exchange gains by XXXX in respect of short and long term debt payable to XXXX and either repaid to XXXX prior to the XXXX reorganization or assumed by Newco as non-share consideration in respect of that reorganization and then repaid. ... We offer the following comments for your consideration: 1. a debt is a property to the creditor (e.g. ...
Miscellaneous severed letter

8 February 1983 Income Tax Severed Letter 5-4737 - [Paragraph 85(1)(e.2)]

A Co. will transfer capital assets, electing adjusted cost base, to B Co. receiving as consideration common shares of B Co. ... However, notwithstanding that fair market value consideration must be received so as to avoid the possible application of paragraph 85(l)(e.2) of the Act the Department is prepared on a case-by- case basis to rule that the provisions of the above paragraph would not be applied where equity is preserved. ...
Miscellaneous severed letter

1 June 1990 Income Tax Severed Letter ACC9086 - Part IV.1 and VI.1 Tax Exemption - Adjustment Formula in Share Redemption not Considered a "Specified Amount"

The share can be redeemed to the extent of this amount without having Part VI.1 and Part IV.1 apply provided the specified amount does not exceed the fair market value of the consideration received. Having the issuer corporation specify the amount was intended to cut down on debates as to the fair market value of the consideration for which the share was issued at some future date when the share is redeemed. ...
Miscellaneous severed letter

17 May 1990 Income Tax Severed Letter ACC9102 - Time Limits for Reassessments

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation, and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that she will receive the utmost consideration possible in the resolution of her case. ...
Miscellaneous severed letter

4 July 1990 Income Tax Severed Letter ACC9471 - Taxation of Pension Payments

Consideration of requests of this nature involve an extensive and fully obiective review of the facts of the particular situation by senior departmental officials in Head Office. ... I wish to assure you that the pensioners will receive the utmost consideration possible in the resolution of their cases. ...
Miscellaneous severed letter

18 April 1990 Income Tax Severed Letter ACC9144 - Request for Remission of Tax

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and the evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of her case. ...
Miscellaneous severed letter

15 May 1990 Income Tax Severed Letter ACC9047 - Time Limit for Reassessments

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation, and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that she will receive the utmost consideration in the resolution of her case. ...
Miscellaneous severed letter

25 May 1990 Income Tax Severed Letter ACC9103 - Tax Remission

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of your case. ...
Miscellaneous severed letter

12 November 1986 Income Tax Severed Letter 5-2071 - [861112]

As part of the consideration the individual receives non-cumulative, redeemable, retractable preferred shares. The redemption amount is a fixed amount equal to the fair market value of the assets transferred to the company less the non-share consideration received. ...

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