Search - consideration

Results 201 - 210 of 13642 for consideration
Technical Interpretation - Internal

30 July 2004 Internal T.I. 2004-0072531I7 - Tax shelters - penalties

Consideration Black's Law Dictionary defines consideration, in part, as follows. ... Thus, in a contract of sale, the money paid or agreed to be paid by the purchaser is the consideration to the vendor, and the property sold is the consideration to the purchaser. ... It is thus our opinion that these loan elements would not constitute consideration. ...
Ruling

2021 Ruling 2021-0911211R3 - Foreign Takeover

Payment of Merger Consideration and Financing of the Acquisition 23. The former holders of Target shares received the Merger Consideration as soon as practicable after the Closing Date. As required by the Merger Agreement, prior to the First Effective Time, XXXXXXXXXX, on behalf of Merger Sub1, caused to be deposited, XXXXXXXXXX, in trust for the benefit of holders of Target shares, the Merger Consideration, XXXXXXXXXX sufficient to pay the aggregate Cash Consideration and evidence of XXXXXXXXXX Common Shares in book-entry form representing the number of XXXXXXXXXX Common Shares sufficient to deliver the aggregate Share Consideration. 24. ... Upon the issuance of the XXXXXXXXXX Common Shares as the aggregate Share Consideration as described in Paragraph 33.ii, XXXXXXXXXX, added to the stated capital account maintained for such common shares an amount equal to the aggregate FMV of the Share Consideration. ...
Technical Interpretation - Internal

1 September 2015 Internal T.I. 2015-0605491I7 - In-kind transfer of property from an RRSP to an IPP

Other Considerations The advantage rules do not appear to have any application to the specific type of transfer that you raise in your letter (i.e. a transfer of property from an RRSP to an IPP in accordance with paragraph 146(16)(a)), but could conceivably apply in other situations where individuals effect transactions between their RRSP and an IPP. ...
Technical Interpretation - Internal

13 September 2001 Internal T.I. 2001-0083067 - HEALTH AND WELFARE TRUSTS

Other Considerations A) The determination of whether a benefit is received by an employee-shareholder in his/her capacity as an employee or as a shareholder involves a finding of fact. ...
Technical Interpretation - Internal

24 January 2001 Internal T.I. 2000-0059517 - DISPOSITION OF PARTNERSHIP AT DEATH

Canadian Resource Property Considerations First of all, it has been the long-standing view of the Department/Agency that an interest in a partnership, the underlying property of which is a Canadian resource property (as defined in subsection 66(15) of the Act), is not a Canadian resource property itself (1). ...
Technical Interpretation - External

28 April 1995 External T.I. 9501085 - TRANSFER OF RRSP FUNDS TO CHARITY ISSUED ANNUITY

Other Considerations: In addition to the rules respecting qualified investments for RRSP's, certain registration requirements will affect the manner in which the annuity purchase is handled. ...
Technical Interpretation - External

25 November 2005 External T.I. 2005-0122351E5 - Service Connection and CRCE

Other Considerations It should be noted that a proposed amendment to Class 17 of Schedule II to the Regulations, which was announced on March 16, 2001, provides that electrical generating equipment (subject to certain exceptions that are not relevant to your situation) acquired after February 27, 2000 will be included in that class by virtue of proposed paragraph (a.1) thereof. ...
Technical Interpretation - Internal

3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef

In determining the value of benefit, one may take its cost into consideration. ... Considération des dépenses de la société pour déterminer la valeur d'un avantage imposable Évaluation de l'avantage imposable en fonction des frais de fonctionnement et de la DPA 68. ... Les considérations du juge nous amènent à conclure qu'une méthode d'évaluation de la valeur d'un avantage fondée sur les frais de fonctionnement et la DPA peut être adéquate dans certaines circonstances pourvu qu'elle se rapproche de la JVM. ...
Technical Interpretation - External

17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project

General Tax Considerations Relating to Different Aspects of the Project 1. ...
Old website (cra-arc.gc.ca)

Calculating Input Tax Credits

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

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