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Results 5191 - 5200 of 8027 for consideration
Conference

9 October 2009 APFF Roundtable Q. 5, 2009-0327001C6 F - Succession canadienne - dividende en capital

This determination must take into consideration all the applicable circumstances including the terms and conditions of the estate. ...
Technical Interpretation - External

23 November 2005 External T.I. 2005-0156071E5 - deductibility of prepayments under s. 18(9.1)

New subsection 18(9.1) also applies to a bonus or penalty, paid in the course of carrying on a business or earning income from property, in consideration of the early repayment of all or part of a borrowing or an unpaid purchase price for property. ...
Technical Interpretation - External

1 November 2002 External T.I. 2002-0146775 - Share Sale by Employees Yields Cap. Gain

Shortly after the purchase of Opco Common Shares from an employee, Newco will transfer such Common Shares to Opco for fair market value consideration. ...
Conference

21 June 2004 STEP Roundtable Q. 3, 2004-0069951C6 - Phantom Income

Where the trust has accrued and reported interest on a debt obligation and has at any particular time disposed of the obligation for consideration equal to its fair market value at the time of disposition, the trust may, by virtue of subsection 20(21) of the Act, deduct in computing income for the year of disposition the over accrued amount; that is the amount, if any, by which the aggregate of the amounts of interest on that debt obligation that were included in the trust's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...
Technical Interpretation - External

21 November 2011 External T.I. 2011-0424331E5 - ITA 110.6(14)(f)

Subparagraph 110.6(14)(f)(i) provides that shares issued as consideration for other shares will not be subject to this special rule. ...
Technical Interpretation - External

7 May 2009 External T.I. 2008-0276181E5 - Stock Option Benefits

Stock Option Benefit Where an option to acquire shares of a public corporation is issued to a non-resident individual as consideration for employment services that are performed in Canada, the benefit received by the individual from the exercise of the option will, by virtue of section 7 and subparagraph 115(1)(a)(i) of the Act, be included in the individual's taxable income earned in Canada in the year in which the shares are acquired. ...
Technical Interpretation - External

14 June 2012 External T.I. 2011-0430131E5 - Subsection 118.1(5) - Gift by Will

In such circumstances, you ask what the date of the gift is, what the issue date of the receipt is, what the correct method of fulfilling the deceased’s bequest is, and whether there are any other special considerations that the charity must consider when completing the official donation receipt for the gift by will. ...
Technical Interpretation - External

15 October 2013 External T.I. 2013-0498001E5 F - Transfert de sommes inutilisées entre régimes

À cet égard, l'alinéa 118.2(2)q) prévoit généralement qu'une prime, une contribution ou autre considération à l'égard d'un particulier ou d'un proche à un RPAM constitue des frais médicaux admissibles. ...
Technical Interpretation - Internal

18 March 2013 Internal T.I. 2012-0470071I7 - Low-cost housing corporation for the aged

This involves both a consideration of the corporation's enabling documents and of the nature of the activities carried on by the corporation. ...
Technical Interpretation - External

15 November 2012 External T.I. 2012-0436061E5 - Is the self-administered HCSA a PHSP?

Therefore, it must represent an undertaking by one person, to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

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