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Technical Interpretation - External

17 January 1990 External T.I. 90M01095 F - Amendments to Provincial Income Tax Acts (Bill C-28)

Reference to 3.1 should be made in section 8 of the Nova Scotia Act. 2)     Section 248(11) on compound interest is amended and consideration should be given to adding the last four lines to section 56(7). ...
Technical Interpretation - Internal

5 June 1990 Internal T.I. 59709 F - Split-dollar Life Insurance

In determining whether an employee/shareholder is in receipt of a benefit in a particular taxation year consideration will be given to the premiums paid by an employee/shareholder, if any, under the policy and the premium cost for equivalent term coverage. ...
Technical Interpretation - External

20 July 1989 External T.I. 58035 F - Definition of Small Business Corporation

" Accordingly, in the situation you have described, it is the corporation's proportionate share of the fair market value of the underlying assets of the partnership that is taken into consideration in determining if the previously mentioned requirement in the definition of "small business corporation" has been satisfied. ...
Administrative Letter

12 March 1990 Administrative Letter 59206 F - Application of Roll-Over Election for Granting of Options

As consideration for the granting of such option, Mr. A. will receive shares of Subco having a fair market value of $10. 3.      ...
Ruling

30 August 1989 Ruling 5-8003 F - Deemed Capital Cost of Property

The comments set out in this letter are of a general nature only and do not take into account considerations that might arise in the context of specific transactions or events. ...
Administrative Letter

7 September 1989 Administrative Letter 57776 F - Insurance Proceeds

In considering the situation described above, no consideration has been given to other tax consequences that may be relevant to the particular situation.  ...
Technical Interpretation - External

7 March 1990 External T.I. 59360 F - Death of Last Annuitant under RRIF

In such cases taxpayers are to submit complete details in writing and a copy of the deceased annuitant's will to the Chief of Verification and Collections in their local district taxation office for consideration. ...
Technical Interpretation - External

12 December 1990 External T.I. 902895 F - Employee's Automobile Allowances

With respect to the question of a "reasonable" allowance under the proposed amendments, it is our tentative view that such questions will be determined on a case by case basis, taking into consideration each employee's circumstances. ...
Ministerial Letter

31 August 1989 Ministerial Letter 57778 F - Canada–Israel Income Tax Convention

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). ...
Technical Interpretation - External

6 September 1990 External T.I. 9009895 F - Asset Write Downs

Your view with respect to this being an anomalous result would more appropriately be addressed to the Department of Finance for their consideration. ...

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