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Results 3281 - 3290 of 13709 for consideration
Technical Interpretation - Internal

28 May 1991 Internal T.I. 910879 F - Limitation on the GST Input Tax Credit for Food, Beverage or Entertainment

Section 236 of the GST parallels section 67.1 of Act and is intended to limit the input tax credit that may be claimed in respect of the consideration payable for food, beverages or entertainment.  ...
Technical Interpretation - Internal

29 June 1990 Internal T.I. 7901287 F - Retirement Compensation Arrangement ("RCA")

Technically, there is nothing in the legislation that provides for the correction requested by 24(1) nor could we find anything in our files to indicate that consideration was previously given to a similar situation.  ...
Technical Interpretation - Internal

26 February 1990 Internal T.I. 59387 F - Reorganization of Capital of Corporation - Exchange of Shares

As stated in question #13 of the 1980 Revenue Canada Round Table, the Department's concern is with the value of the shares received as consideration, either for shares transferred to the corporation, pursuant to subsection 85(1), or for the shares disposed of as part of a reorganization pursuant to subsection 86(1) of the Act.  ...
Technical Interpretation - External

26 March 1990 External T.I. 90M03220 F - Remission of Unpaid Tax and Interest

However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of the unpaid taxes and interest described in your letter of July 5, 1989 to The Honourable Harvie Andre. 24(1) While the situation may be considered to be unfortunate, I have not found any indication that the assessments arose for reasons that would not apply to other taxpayers in similar circumstances or that any unfairness was involved with regard to the application of the law.  ...
Technical Interpretation - Internal

27 March 1990 Internal T.I. 74729 F - Gifts Qualifying as Charitable Donations

As you are aware, a gift is a voluntary and gratuitous transfer of real or personal property without consideration.  ...
Administrative Letter

18 January 1990 Administrative Letter 59236 F - Payments to Foster Parents

Szeszycki   (613) 957-2103 January 18, 1990 Dear Sirs: Re:  Payments to Foster Parents We are responding to your letter of September 18, 1989 addressed to the District Taxation Office in Vancouver which was forwarded to this office for consideration and reply.  ...
Technical Interpretation - Internal

12 January 1990 Internal T.I. 59237 F - Payment of Legal Fees

Although we leave the final determination in your hands, we are providing the following comments for your consideration. ...
Ministerial Letter

23 January 1990 Ministerial Letter 59098 F - Employee Share Purchase Plan

Harding   (613) 957-3499 January 23, 1990 Dear Sirs: Re:  Employee Share Purchase Plans This is in reply to your letter of November 15, 1989 wherein you requested our consideration of a proposed model share purchase plan. ...
Miscellaneous severed letter

7 June 1989 Income Tax Severed Letter 7-3749 - [Application of Subsection 69(3)]

Therefore, in order to determine whether subsection 69(3) would or would not apply for those guarantee agreements entered into prior to May 10, 1985 for no consideration, it is necessary to review and examine the terms and conditions of the particular guarantee agreements. ...
Miscellaneous severed letter

19 May 1988 Income Tax Severed Letter 5-5745 - [Determination of Capital Cost]

You asked whether the capital cost of property acquired in this manner would be 1) the cost to the transferee as determined under subsection 85(1) or 97(2) or 2) the value of all consideration given, including shares of the transferee, for the acquisition of the particular property. ...

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