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Results 3151 - 3160 of 13706 for consideration
Technical Interpretation - External

25 January 1999 External T.I. 9828335 - RESP QUALIFIED INVESTMENTS

Should you feel the provisions are unfair to a specific financial sector we suggest that it would be appropriate for you to submit details of your concerns to the Department of Finance for their consideration. ...
Technical Interpretation - External

28 January 1999 External T.I. 9830825 - SUPERFICIAL LOSS - RRSP

With respect to GAAR, this is clearly an issue that would require further consideration. ...
Technical Interpretation - External

3 March 1994 External T.I. 9404985 - INDIANS - PRORATION FORMULA FOR EMPLOYMENT INCOME

In prorating the employment income to determine the tax-exempt portion, vacation leave and statutory holidays can be taken into consideration in the pro-rating formula. ...
Technical Interpretation - External

29 April 1994 External T.I. 9403905 - FORGIVEN DEBTS

Position TAKEN: Agreed with taxpayer and advised him that section 80 was under consideration by Finance Reasons FOR POSITION TAKEN: Had the taxpayer accrued the liabilities he would have had losses to apply the section 80 amount against before reducing the cost of his depreciable assets. 940390 XXXXXXXXXX A.M. ...
Technical Interpretation - External

13 May 1994 External T.I. 9406295 - CLASS 34 - LANDFILL GAS - MUNICIPAL WASTE

Accordingly, this issue was referred on March 25, 1994 by XXXXXXXXXX of your firm to Energy, Mines & Resources Canada for their consideration, and we have closed our file. ...
Technical Interpretation - Internal

9 May 1994 Internal T.I. 9409347 - SHARES ISSUED FOR DEBT

" Accordingly, to the extent that the FMV of the share consideration received by XXXXXXXXXX is less than the principal amount of the debt settled, subsection 80(1) will apply to the difference. for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...
Technical Interpretation - Internal

20 April 1994 Internal T.I. 9409700 - RETIRING ALLOWANCE - PARTNERSHIP

In consideration for resigning from the employment position the partnership pays the employee a termination payment immediately prior to joining the partnership. ...
Technical Interpretation - External

26 July 1994 External T.I. 9415675 - CAPITAL DIVIDEND ACCOUNT

The comments set out in this letter are of a purely general nature and do not take into account any considerations which might arise in the context of a specific transaction. ...
Ruling

23 September 1994 Ruling 9409403 - ELECTION TO RECEIVE CASH IN LIEU OF SHARES UNDER SEC 7

Nevertheless, and as also discussed with XXXXXXXXXX, it is our view that the provisions of paragraph 7(1)(b) would be applicable at the time any employee elected to receive cash consideration for an option to acquire shares. ...
Technical Interpretation - External

17 November 1994 External T.I. 9428725 - RRSP RECEIPTS FOR GIFTS

At law a gift is a voluntary transfer of property without consideration; a premium is basically an amount paid in order to obtain a "retirement income" (defined in subsection 146(1) of the Act). ...

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