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Results 3941 - 3950 of 13711 for consideration

30 June 1989 Internal T.I. 32449 F - Whether or not Discount on Issuance of a Zero-coupon Bond Would be Interest

If the parties decide to proceed and provide us with the necessary documentation we would be pleased to reopen the file and give it priority consideration. ...

14 June 1990 Ruling 59643 F - Shareholder Benefits - Respect of Single Purpose Corporations

The consideration for the transfer would be common shares of the corporation with a fair market value equal to the value of the residential property at the time of the transfer. ...

26 April 1991 Ministerial Letter 9107418 F - Basic Exemption of Multiple Trusts

The wording of the trust agreement (page 1) 24(1) 24(1) As indicated in paragraph 5 of IT-374, a contribution equals the excess of the fair market value of the property over the fair market value of the consideration given. 24(1) for DirectorFinancial Industries DivisionRulings Directorate ...

24 November 1989 External T.I. 58750 F - Indian Fishermen

Although such a determination can only be made after an examination of all the facts and consideration of the above criteria it would appear based on the limited information provided that the Indian in your fact situation had his principal place of business in his home. ...

23 April 1991 Internal T.I. 903089 F - Private Health Service Plans

" As stated in paragraph 3 of Interpretation Bulletin IT-339R2, the PHSP must contain the following basic elements: (a) an undertaking of one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

16 November 1990 External T.I. 900405 F - Partnership as a Person

The Partnership will pay to L Ltd. consideration equal to the Property's fair market value in exchange for the Property. ...

2 October 1990 External T.I. 59825 F - Adjusted Cost Base of Capital Interest in a Trust

Should you have a specific case under consideration we suggest that you request a ruling. ...

13 December 1989 Ruling 74363 F - Residence

We offer the following comments for your consideration: I. Directive 1. ...

25 October 1990 Ruling 900841 F - Deductibility of Single Premium for Paid-up Group Term Insurance

Our Comments Subparagraph 18(9)(a)(iii) of the Income Tax Act states in its context, that: "Notwithstanding any other provision of this Act... no deduction shall be made in respect of on outlay or expense to the extent that it can reasonably be regarded as having been made or incurred... as consideration for insurance in respect of a period after the end of the year (other than an amount paid in respect of reinsurance by an insurer)". ...

3 June 1991 Internal T.I. 910947 F - Shareholder Debt

Whether bona fide arrangements were made at the time the housing loan was made, for repayment of that loan within a reasonable period of time, is a question of fact that can only be determined upon consideration of all the circumstances of a particular taxpayer's case. ...

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