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Results 5491 - 5500 of 8026 for consideration
Miscellaneous severed letter

9 June 1997 Income Tax Severed Letter 9714705 - Twenty one year rule — see 970488

While Revenue Canada does not have the authority to grant your request, we offer the following comments for your consideration. ...
Ruling

30 November 1996 Ruling 9641563 - STRUCTURED SETTLEMENTS

In consideration of Insurers A and B making such payments, the Claimant settles XXXXXXXXXX claims against the Defendants and Insurers A and B. ...
Technical Interpretation - External

27 February 1997 External T.I. 9641685 - PRIN RES -TRANS OF EXCESS LAND BETWEEN NEIGHBOURS

A request for subdivision submitted by a group of neighbours in the area, including the taxpayers, is currently under consideration by the municipality. ...
Technical Interpretation - Internal

8 July 1997 Internal T.I. 9717116 - EDUCATION CREDIT - FULL-TIME ENROLMENT

If the institution determines that your status should be revised and provides you with certification to this effect, you may submit this documentation, along with a request for adjustment to your tax returns for the relevant taxation years, to your local Tax Services Office for consideration. ...
Ruling

30 November 1995 Ruling 9609153 - PROPERTY...IN WHICH THE BUSINESS... IS CARRIED ON"

The Series XXXXXXXXXX preferred shares were issued for $XXXXXXXXXX for cash consideration XXXXXXXXXX. ...
Technical Interpretation - External

9 December 1996 External T.I. 9611945 - CALCULATION OF SAFE INCOME FOR FOREIGN AFFILIATE

The consideration received by Opco from Holdco was redeemable retractable preferred shares having an aggregate redemption amount equal to the fair market value of the USCo shares acquired by Holdco. ...
Ruling

30 November 1995 Ruling 9611983 - APPLICABILITY OF WITHOLDING EXEMPTION UPON WINDING UP

Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...
Technical Interpretation - External

7 March 1997 External T.I. 9621945 - STATUS AS A NRO

Other considerations would include the implications of subsection 18(4) of the Act with respect the interest deduction being claimed by Opco. ...
Ruling

30 November 1995 Ruling 9625113 - TRANSFER OF FARM PROPERTY

XXXXXXXXXX and Holdco, and XXXXXXXXXX and Holdco, will jointly elect, within the time and in the manner prescribed by subsection 85(6), to effect the transfer of XXXXXXXXXX under section 85 at an agreed amount equal to the adjusted cost base of their respective interests in XXXXXXXXXX, plus an amount equal to that which can be sheltered by their respective remaining lifetime capital gains exemptions for qualified farm property, up to the fair market value of XXXXXXXXXX. 13.As consideration for XXXXXXXXXX, Holdco will issue a non-interest-bearing promissory note to each of XXXXXXXXXX having a principal amount equal to the agreed amount, and will issue redeemable retractable preferred shares in its capital stock to each of XXXXXXXXXX having a redemption amount and fair market value equal to the difference between the fair market value of XXXXXXXXXX and the principal amount of the promissory note. ...
Ruling

30 November 1995 Ruling 9631383 - STRUCTURED SETTLEMENTS

In consideration of the Insurer making such payments, the Claimants settle their claim against the Insurer. ...

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