Search - consideration

Pursuant to a written agreement and in consideration for a fair market value fee, Partnership F will provide the Contracting Companies with certain supplies, personnel, facilities and equipment that are required to provide XXXXXXXXXX Services. ...

(E) The particular trust will qualify as a personal trust since First Nation will be the settlor and the interest will not be acquired for any consideration. ...

Pursuant to a written agreement and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the XXXXXXXXXX Services. ...

However, in the situation under consideration, the opinion expressed was that the native gas and any purchased gas injected into the underground storage area to build up the pressure to the required base pressure level at the time that the area was developed as a storage facility would constitute depreciable property. ...

À cet égard, entre autres choses, les termes de l'acte constitutif de la fiducie, le registre des actionnaires de même que toute convention unanime entre actionnaires sont des éléments qui doivent être pris en considération. ...

In consideration for the signature of the exclusivity clause, BCo pays an amount of $1.5M to ACo at the time of the signature of the Agreement. ...

The latest Transition Date was determined based on a formula set out in the XXXXXXXXXX Agreement that took into consideration the number of years of service of the XXXXXXXXXX Member. ...

On XXXXXXXXXX, Parentco will sell all of the issued and outstanding shares of Lossco to Profitco for cash consideration equal to the aggregate FMV of the shares at that time. ...

(Canadian Tax Foundation); "International Taxation in the Age of Electronic Commerce: A Comparative Study" by Jinyan Li, (Canadian Tax Foundation); The OECD Discussion Draft on the Attribution of Profits to Permanent Establishment- Part I (General Consideration) (Paris, OECD, August 2004); "Subject II: The Attribution of Profits to Permanent Establishments" (Canadian Branch Report) by Marc Darmo and Carrie Smit, IFA Congress 2006 Amsterdam; "Global Profit Split: An Evolutionary Approach to International Income Allocation" by Jinyan Li, (2002, vol. 50, no.3 Canadian Tax Journal, 823-867); "Rethinking Canada's Source Rules in the Age of Electronic Commerce: Part 1", by Jinyan Li (1999, vol. 47, no. 5 Canadian Tax Journal, 1077-1125); "Rethinking Canada's Source Rules in the Age of Electronic Commerce: Part 2", by Jinyan Li, (1999, vol. 47, no.6 Canadian Tax Journal, 1411-1478); "Summary of Proceedings of an Invitational Seminar on the Attribution of Profits to Permanent Establishments" by Brian Arnold and Marc Darmo, (2001, vol. 49, no. 3, Canadian Tax Journal, 525-552); "The OECD Project: Transfer Pricing Meets Permanent Establishment", by Robert Couzin, (2005, vol.53, no. 2 Canadian Tax Journal, 401-408); and "Transfer Pricing and Attribution of Income to Permanent Establishments: The Case for Systematic Global Profit Splits (Just Don't Say Formulary Apportionment)", by Francois Vincent, (2005, vol. 53, no. 2 Canadian Tax Journal, 409-416). 2 Supra, footnote 1. 3 This approach is based on transactions such as using the traditional comparable uncontrolled price method (CUP), resale-price method and cost-plus method of transfer pricing 4 For example, Jinyan Li and Francois Vincent; see their respective articles referred to in note 1. 5 International Harvester Company of Canada Ltd. v. ...

2006 Ruling 2006-0180261R3 F- In-House Loss Utilization Unedited CRA Tags 55(3)(a) 111(1) 84(3) Principal Issues: Transfer on a tax-deferred basis of shares of the capital stock of a corporation by Profitco in favour of Lossco, in consideration for preferred shares of the capital stock of Lossco. ...