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Results 471 - 480 of 8027 for consideration
Miscellaneous severed letter

25 July 1989 Income Tax Severed Letter AC73992 - Reclassification of Wages as Dividends

Employment income received by an employee is a valuable consideration for services he renders under a written or verbal employment contract. Dividend income received by shareholders is, in our view, a pro-rata distribution by a corporation among its shareholders of its income or capital gains, as consideration for the capital the shareholders have invested by buying shares of the corporation. ...
Miscellaneous severed letter

23 October 1991 Income Tax Severed Letter

Prosia, we are forwarding for your consideration and reply the August 15, 199], letter from the law firm of 24(1) oncerning the possible application of the above noted penalty provisions to situations where an individual fails to copy with the requirements of 159(2) and thus becomes liable under 159(3). ... Prosia, he indicated that to the best of his knowledge, the above noted penalty provisions are not given consideration in connection with the collection procedures instituted as a result of the application of 159(3). ...
Miscellaneous severed letter

4 July 1990 Income Tax Severed Letter ACC9472 - Request for Relief on Tax

Consideration of requests of this nature involve 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 you will receive the utmost consideration possible in the resolution of their cases. ...
Miscellaneous severed letter

6 April 1990 Income Tax Severed Letter ACC9142 - Remission of Late-filing Penalties

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 he will receive the utmost consideration possible in the resolution of this case. ...
Miscellaneous severed letter

22 May 1985 Income Tax Severed Letter 5-7532 - [Paragraphs 85(1)(e.2) and 15(1)(b)]

Opco's consideration is a note for $800 and a preference share redeemable and retractable for $1. In our opinion, paragraph 15(1)(b) of the Act would apply to include an amount in Holdco's income as property has been appropriated from Opco for the benefit of Holdco to the extent of the excess of the fair market value of the asset transferred over the fair market value of the consideration received by Opco. ...
Miscellaneous severed letter

15 May 1990 Income Tax Severed Letter ACC9045 - Time Limit for Assessment

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 19(1) will receive the utmost consideration possible in her case. ...
Miscellaneous severed letter

12 April 1990 Income Tax Severed Letter ACC9145 - 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 a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that he will receive the utmost consideration possible in the resolution of his case. ...
Miscellaneous severed letter

13 May 1992 Income Tax Severed Letter 920412 - Social Assistance Payments - Self-Managed Care Project of Alberta

As a result the payments would be included in the individual's net income which is taken into consideration in calculating the refundable tax credits. ... In view of the policy implications, we have forwarded a copy of your letter to officials of the Department of Finance for their consideration and have asked them to reply directly to you. ...
Ruling

17 October 2012 Ruling 2010-0376681R3 - Internal reorganization - 55(3)(a)

The shareholders of Opco will not receive any non-share consideration on the merger. ... As consideration, Amalco will issue a demand, non-interest bearing, promissory note (“Note10”) with a principal amount equal to the FMV of the shares redeemed. 59. ... As consideration, Amalco will issue a demand, non-interest bearing, promissory note (“Note11”) with a principal amount equal to the FMV of the shares redeemed. 60. ...
Ruling

2004 Ruling 2004-0081531R3 - XXXXXXXXXX - Internal Restructuring

Parent will transfer to Transferee that number of issued and outstanding common shares of Distributing which have an aggregate fair market value equal to the fair market value of the Newco Common Shares, in consideration for the issue by Transferee to Parent of additional common shares. ... Distributing will transfer to Transferee the common shares of Cansub1 in consideration for cash in an amount equal to XXXXXXXXXX and the issue by Transferee to Distributing of a number of spin off preferred shares having an aggregate fair market value equal to the aggregate fair market value of the common shares of Cansub1 less the amount of cash consideration paid by it to Distributing. ... As consideration for the transfer of the XXXXXXXXXX Shares by Distributing to Transferee, Transferee will issue to Distributing a number of spin off preferred shares having an aggregate fair market value equal to the fair market value of the XXXXXXXXXX Shares so transferred to it. ...

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