Search - consideration

These comments are general in nature and do not specifically take into consideration the facts in the hypothetical situation which you outlined. ...

We confirm that this provision would be given prime consideration when determining whether or not the partnership interest is a "carve-out property". ...

Tax Executive Institute Round Table Author: Steve Tevlin Date: October 15, 1992 Document Type:Code 7 T236 #: 923039 Question: A taxable Canadian corporation (the "Issuer") issues, for cash consideration, a bond warrant (the "Option") that grants the investors an option to acquire a debenture with cash flows and terms identical to those of an existing callable debenture. ...

With respect to your second question, the determination of the fair market value of escrowed shares is a question of fact which can only be determined by giving consideration to all the facts in the situation. ...

Guglich (613) 957-2102 Attention: XXXXXXXXXX December 23, 1992 Dear Sirs: Re: Bequeath to a Foundation This is in reply to your letter of November 3, 1992 wherein you request our views regarding three hypothetical scenarios involving a taxpayer and XXXXXXXXXX Scenario 1 The payment of $2,000.00 per month by the Foundation to the friend of the taxpayer could be regarded as consideration for the loan of the property to the Foundation and would be required to be included in the friend's income for the year. ...

Are there any policy considerations requiring an exemption from section 80.4 where subsection 15(8) would apply? ...

Our Opinion The amount of child care expenses that should be claimed in those years is the amount the taxpayer is allowed to deduct after taking into consideration the amount of child care subsidy the taxpayer should have received based on gross income (i.e. after the Services discovered the taxpayers' understatement of income). ...

However, after further review and consideration we realize that the payments would automatically be included in the income of a farmer or farm business as business income under section 9 of the Act and it would not be necessary to invoke paragraph 12(1)(x). ...

Comments Whether or not a property can be characterized as a capital property depends upon a consideration of the facts surrounding the acquisition of the property and the holding of such property. ...

Based on the Department's comments in paragraph 21 of Information Circular 70-6R2 regarding requests in respect of a contemplated or completed transaction, we are prepared to offer the following general comments: Where a partnership is wound up under subsection 98(3) of the Act, it is our administrative practice to allow a reserve pursuant to subparagraph 40(1)(a)(iii) (subject to the limitations of subsection 40(2) of the Act) to be Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information claimed by a former member in respect of an interest in an outstanding debt receivable that the member received in consideration for the member's partnership interest. ...