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Results 3251 - 3260 of 13708 for consideration

5 January 1990 External T.I. 58720 F - Interest Income Earned Under a Conditional Sale Contract

The determination of whether a money-lending business is being carried on is a question of fact which requires a full knowledge of the relevant circumstances of the particular case under consideration. ...

16 January 1990 External T.I. 74580 F - Reporting Requirements Respecting Convertible Securities

Provided the convertible securities and conversion options are "securities" within the meaning of the term under subsection 230(1) of the Regulations, the reporting requirements under section 230 of the Regulations are applicable in respect of purchases, sales, redemptions, acquisitions or cancellations of the convertible securities and convertible options, with the following exceptions: (a) cases where subsection 230(7) is applicable, or (b) transactions to which section 51, 86 (where there is no consideration receivable other than new shares) or 87 subsection 98(3) or (6) of the Act is applicable. 21(1)(b) DirectorFinancial Industries DivisionRulings Directorate ...

20 August 1991 External T.I. 911710 F - Amounts Paid or Credited or Deemed to be Paid or Credited by a Trust to a Non-Resident Beneficiary

An opinion in respect of a particular situation can only be formulated after determining and considering all of the relevant facts, including the terms of the particular trust under consideration, the amount payable to the beneficiaries thereunder and the amount in fact paid to the beneficiaries. ...

14 November 1990 External T.I. 9024865 F - Transfer of Property Under the Family Law Act

Where the surviving spouse reaches a settlement with the executors and beneficiaries of the estate that property in the deceased's estate will be transferred to the surviving spouse in consideration of a release of his or her rights to make a claim under the FLA for an equalization of net family property, it is our view that the transfer would not be considered a transfer as a consequence of the death of the deceased. ...

10 June 1991 Ruling 910943 F - Manufacturing and Processing Tax Credit

There may have been consideration given to this subject in other areas of the Department. ...

22 October 1990 Internal T.I. 901919 F - Family Farm Partnerships

We have, however, brought the matter to the attention of the Department of Finance for their consideration. ...

1 October 1990 External T.I. 9024345 F - Charitable Gifts

As explained in paragraph 3 of IT-110R2 (Special Release), a gift, for purposes of sections 110.1 and 118.1 of the Act, is a voluntary transfer of property without valuable consideration. ...

6 November 1990 Ruling 901091 F - Deemed Majority Interest Partner

The corporation sells capital property to the partnership and receives from the partnership consideration equal to the fair market value of the property at the time of the transfer. ...

3 December 1990 Internal T.I. 903329 F - Transfer of Debt Property to Corporation by Shareholder

Tevlin (613) 957-2118 19(1) December 3, 1990 Dear Sirs: Re: Subsection 85(1) and Section 80 of the Income Tax Act (the "Act") This is in response to your request for a technical interpretation contained in your letter of November 19, 1990, wherein you requested our opinion as to whether the provisions of subsection 85(1) of the Act would apply where a corporate taxpayer disposes of a debt obligation, to the debtor who is a taxable Canadian corporation, and receives newly issued shares of the debtor corporation as consideration for the transfer. ...

6 September 1991 External T.I. 912120 F - Charitable Donations

A gift may be defined as a voluntary transfer of property without consideration. ...

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