Search - consideration

Results 2491 - 2500 of 13640 for consideration

10 September 1982 Income Tax Severed Letter RCT 5-4206 F

The property is transferred from A Co. to B Co. electing an amount equal to cost under subsection 85(1)(a) of the Income Tax Act, the consideration being the assumption by B Co. of an existing mortgage approximately equal to the "cost amount" of the property and one preferred share having a par value and a redemption amount of $1.00. ...

12 February 1980 Income Tax Severed Letter RCT 85-43

This transaction would be effected pursuant to subsection 85(1) of the Act and in consideration of the transfer of property, the corporation would issue a note payable equal to the aggregate of the undepreciated capital cost of the building and 90% of the estimated adjusted cost base of the land. ...

8 June 1981 Income Tax Severed Letter RCT 89-120

We regret that we cannot provide you with examples; a particular situation will be analysed taking into consideration all relevant facts. ...

18 December 1987 Income Tax Severed Letter RCT 7113-4

The Corporation will sell its commercial rental properties to the Partnership pursuant to a subsection 97(2) election, for fair market value consideration consisting of debt assumption and Class B units in the Partnership with an aggregate redemption amount equal to the excess of the fair market value of the properties over the amount of debt assumed. ...

30 April 1987 Income Tax Severed Letter RCT 5-3054 F

As you correctly point out, in a situation where subsection 85.1(3) of the Act has application and where the sole consideration for the above-mentioned transfer of shares is shares of the acquiring affiliate, the taxpayer's deemed proceeds of disposition under paragraph 85.1(3)(c) for the transferred shares will be equal to the aggregate of the adjusted cost bases of such transferred shares. ...

6 March 1981 Income Tax Severed Letter RCT 89-133

After taking into consideration the comments that we have received from persons concerned with our position, we have concluded that a change in our assessing practice along the lines indicated in the Revenue Round Table could provide undesired and unfair results. ...

31 July 1989 Income Tax Severed Letter 3-2574 - Whether Revenue Canada will rule on if a pooled fund to be created will qualify for registration pursuant to subsection 204.4(2)

We suggest that you make application for registration as a Registered Investment using prescribed From T2217, and submit it to our Registered Pension and Deferred Income Plans Division for consideration. ...

17 April 1990 Income Tax Severed Letter 7-4740 - Acquisition of loss company

It is also our view, however, that consideration should be given to the application of the provisions of section 79 to the transactions XXX. ...

31 August 1989 Income Tax Severed Letter 5-7778 - Disposition of shares by non-resident—Article XIII of the Canada-Israel Income Tax Convention, 1976

The foregoing opinion is based on the assumption that this is a fact situation where Part XVI of the Act was not a consideration (i.e., this corporate structure was in place for a number of years). ...

31 March 1992 Income Tax Severed Letter 9203015 - Prescribed shares

Whether either subclause is satisfied will be a question of fact, the determination of which will require a consideration of all the circumstances and not only the terms of the employee share purchase agreement. ...

You are here