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Results 3861 - 3870 of 13642 for consideration
Technical Interpretation - External

6 June 2001 External T.I. 2001-0079765 - Pre-production revenue and expenses

Where paragraph 66(12.1)(a) applies, a taxpayer's "cumulative Canadian exploration expenses is reduced by consideration received (including revenue from a bulk sample where the original cost relates to CEE of the taxpayer). ...
Technical Interpretation - External

6 July 2001 External T.I. 2001-0085535 - DEFINITION OF ANNUITANT UNDER RRIF

In general, a RIF is an arrangement between a carrier and an annuitant under which, in consideration for property, the carrier undertakes to pay the yearly minimum amount to the annuitant and, where the annuitant so elects, to the annuitant's spouse or common-law partner after the annuitant's death. ...
Technical Interpretation - External

14 October 2001 External T.I. 2001-0098185 - TRANSFER OF LIFE INS. TO CHILD

Subsection 148(8) of the Act provides that where an interest of a policyholder in a life insurance policy is transferred to a child of the policyholder for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of disposition equal to the adjusted cost basis to the policyholder of the interest immediately before the transfer and to have been acquired by the child at a cost equal to that amount. ...
Technical Interpretation - Internal

28 November 2001 Internal T.I. 2001-0108517 - Treaties Whether trust is individual

This interpretation would generally prevail across most if not all of Canada's income tax conventions that have been crafted by reference to the Model if the definition of "person" in the particular convention under consideration makes reference to both an "individual" and a "trust". ...
Technical Interpretation - External

28 December 2001 External T.I. 2001-0101085 - TRUSTEE LIABLE FOR PART XI TAX

During our telephone conversation of October 23, 2001 (XXXXXXXXXX/Kohnen), we advised that if we were provided with complete disclosure concerning the client in question, we would forward the information to the Assessment and Collections Branch for their consideration. ...
Ministerial Correspondence

10 December 2001 Ministerial Correspondence 2001-0110284 - FORMAL CONSULTATIONS WITH JUSTICE

Brian Ernewein, Director of the Tax Legislation Division at the Department of Finance, for his consideration. ...
Technical Interpretation - External

18 January 2002 External T.I. 2001-0108215 - SHARES OF A QUAL. FARM PROPERTY

Does the asset test in the definition of "share of the capital stock of a family farm corporation" in 110.6(1) include assets used by a corporation related to the corporation under consideration? ...
Technical Interpretation - External

25 April 2002 External T.I. 2002-0128985 - MANAGEMENT BONUS PAID TO ESTATE

Our Comments As a general rule, the deduction of all expenses is subject to the test of reasonableness in section 67 of the Act, and the question of whether this provision applies in an actual situation can only be determined after a consideration of all of the facts. ...
Technical Interpretation - External

8 May 2002 External T.I. 2002-0129075 - EARLY REDEMPTION CHARGE - RRIF

Under the terms of its registration, a RRIF cannot accept property as consideration thereunder other than property transferred in accordance with subparagraphs 146.3(2)(f)(i) to (vii) of the Act. ...
Technical Interpretation - External

3 July 2002 External T.I. 2002-0141305 - SH-MANAGER BONUS AT END OF BUS.

As a general rule, the deduction of all expenses is subject to the test of reasonableness in section 67 of the Income Tax Act, and the question of whether this provision applies in an actual situation can only be determined after a consideration of all of the facts. ...

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