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Technical Interpretation - External

18 May 1999 External T.I. 9908365 - UNUSED TUITION AND EDUCATION TAX CREDITS

This is deficient, as you have pointed out, because there are other tax credits (e.g. dividend tax credit) that should be taken into consideration. ...
Ministerial Correspondence

21 May 1999 Ministerial Correspondence 9910244 - MECHANIC'S TOOLS

In this regard, I note that XXXXXXXXXX has forwarded a copy of your letter to the Honourable Paul Martin, Minister of Finance, for his consideration. ...
Technical Interpretation - External

4 June 1999 External T.I. 9907505 - APPLICATION OF 118.1(16)

For example, consideration would have to be given to the reason why the income allocation to the private foundation was made by way of note rather than cash. ...
Technical Interpretation - External

12 July 1999 External T.I. 9915895 - WHETHER CONTRIBUTION TO A TRUST IS A GIFT

As stated in paragraph 3 of IT-110R3, a gift, for the purposes of sections 110.1 and 118.1 of the Income Tax Act, is a voluntary transfer of property without valuable consideration. ...
Technical Interpretation - External

15 July 1999 External T.I. 9911175 F - EMPLOYÉ - ACTIONNAIRE UNIQUE -207.6(2)

PRINCIPALE QUESTION: Basé sur l’opinion 970722, un employé actionnaire unique dont la société souscrirait à une police d’assurance sur sa propre vie ne pourrait sous aucune considération rencontrer les conditions d’application de 207.6(2). ...
Technical Interpretation - External

4 August 1999 External T.I. 9918345 - GAIN ON DISPOSITION OF DEBT OBLIGATIONS

In the particular case under consideration, the adjusted cost base applicable to the part disposition would be equal to that proportion of entire adjusted cost base of the debt obligation immediately prior to the part disposition that the payment received is of the outstanding principal amount of the obligation at that same time. ...
Ministerial Correspondence

24 April 2019 Ministerial Correspondence 2019-0798971M4 - CCA class for zero-emission / electric vehicles

Therefore, you may want to direct future queries relating to tax policy to the Department of Finance for their consideration. ...
Conference

3 December 2019 CTF Roundtable Q. 4, 2019-0824521C6 - 84.1(1)(a) v/s 129(1)(a)

A transfers his shares of the capital stock of Opco 1 to Opco 2 in consideration for a note. ...
Ministerial Correspondence

25 August 2020 Ministerial Correspondence 2020-0854171M4 - Canada caregiver credit & spousal income

Therefore, I am sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...
Technical Interpretation - Internal

3 May 2021 Internal T.I. 2021-0875571I7 - CERS - Boat Slips as Immovable Property

In general, such a determination under either common law principles or the CCQ remains a question of fact that would require consideration of various factors, including the degree or permanence of the annexation to the land or ground (i.e., whether it has become a fixture or structure), the purpose of the annexation, and the nature of the property. ...

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