Search - consideration

Consequently, an interest in a Wyoming LLC receivable by a taxpayer as consideration for the disposition of the shares of the capital stock of a foreign affiliate to the LLC would constitute "shares of the capital stock of the acquiring affiliate" provided that the LLC would otherwise qualify as a foreign affiliate of the taxpayer immediately after the disposition. ...

XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: Re:  Transfer of Property We are writing in response to your letter dated August 12, 1992 wherein you requested our opinion as to whether a research and development tax pool (the "R&D Pool") would be eligible to be transferred pursuant to the provisions of subsection 85(1) of the Income Tax Act 1 in exchange for share consideration. ...

As such amendments are the responsibility of the Honourable Paul Martin, Minister of Finance, it was appropriate that you also sent him a copy of your correspondence for consideration. ...

In order to qualify under the definition of a "specified deposit", paragraphs (a) and (b) in proposed subsection 95(2.5) require that the income from the deposit under consideration would, but for proposed paragraph 95(2)(a.3), be income from an active business carried on by the foreign affiliate. ...

The Product is purchased by Salesco for fair market value consideration. ...

Martin, I am certain your views will receive every consideration. I am, however, pleased to advise you that in a press release on July 19, 1995, releasing the draft legislation pertaining to the budget, Mr. ...

Should you wish to advise us of your specific concerns we will give them consideration and provide you with our comments. ...

Sarazin Attention: XXXXXXXXXX January 4, 1996 Dear Sirs: Re: Retiring Allowances This is in reply to your letter dated September 25, 1995 and addressed to the Source Deductions Section of the Toronto Tax Services Office which was forwarded to us for our consideration. ...

Whether property is inventory or capital property is always a question of fact and it appears that your particular situation received due consideration by the Department in resolving this issue. for Director Business and General Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Although consideration of such relief is not a function performed by the Income Tax Rulings Directorate, we have discussed the situation with officials of the Assessment and Collections Branch who have requested that we forward your correspondence to their attention. ...