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Results 3291 - 3300 of 13709 for consideration
Miscellaneous severed letter
10 January 1992 Income Tax Severed Letter 9122210 F - Taux de rendement annuel
Est-ce que le dividende doit être calculé sur la valeur des actions au moment du transfert, soit la considération reçue lors de leur émission? ...
Miscellaneous severed letter
28 May 1992 Income Tax Severed Letter 9215968 - Two-tiered Partnership - Active Business Income
However, these are separate issues from the issue under consideration involving the characterization of active business income in a two-tier partnership and the answer given at the 1991 Roundtable is so restricted. ...
Miscellaneous severed letter
15 April 1992 Income Tax Severed Letter 9205275 - Transfer of Retiring Allowance to RRSP
The number of years with the previous employer that would count for the purposes of clause 60(j.1)(ii)(A) of the Act would be those years of service with the previous employer that were taken into consideration in determining the amount of the pension benefits. ...
Miscellaneous severed letter
17 August 1992 Income Tax Severed Letter 9212475 - Charitable Donations - Reimbursed Expenses
In paragraph 3 of IT-110R2 it states that "A gift, for purposes of sections 110.1 and 118.1, is a voluntary transfer of property without valuable consideration." ...
Miscellaneous severed letter
14 December 1992 Income Tax Severed Letter 9227805 - Income vs. Capital Gain
Please note that no consideration has been given herein as to whether the property is qualified farm property. ...
Miscellaneous severed letter
31 August 1989 Income Tax Severed Letter AC57778 - 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). ...
Miscellaneous severed letter
21 August 1990 Income Tax Severed Letter ACC9287 - Repayment of Loans and Advances by Shareholder
In this situation, the payer corporation has provided valuable consideration with no reasonable expectation of repayment. ...
Miscellaneous severed letter
14 May 1990 Income Tax Severed Letter AC59659 - Disbursement Quota of Charity
This matter has been brought to the attention of the Department of Finance for consideration of an appropriate technical amendment. ...
Miscellaneous severed letter
25 July 1990 Income Tax Severed Letter ACC9395 - Early Redemption of Guaranteed Investment Certificates
Where a taxpayer has accrued and reported interest income on a debt obligation and has at any particular time disposed of that obligation for consideration equal to its fair market value at the time of disposition, the taxpayer may, by virtue of subsection 20(21) of the Act, deduct in computing income for the year of disposition, the amount, if any, by which the aggregate of the amounts of interest from that debt obligation that was included in the taxpayer's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...
Miscellaneous severed letter
18 May 1988 Income Tax Severed Letter 7-2615 - [880518]
Nelson (613) 957-8284 SUBJECT: XXXX We are writing in reply to your memo of March 2, 1988, concerning the deductibility of interest expenditures incurred by XXXX under a loan guarantee arrangement with XXXX Facts XXXXXXXXXXXX D.O Position XXXX loan guarantee was given for no consideration and therefore interest paid on XXXX Bank loan used to honour its guarantee was not laid out for the purpose of gaining or producing income and is not deductible pursuant to paragraph 20(1)(c) of the Act. ...