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Technical Interpretation - Internal

12 September 1997 Internal T.I. 9721247 - INDIAN EMPLOYEE NOT REQUIRED TO WORK ON RESERVE

That is, for purposes of the Guidelines that take into consideration the location where the duties of employment are performed, in our view, the most relevant locations are the locations at which the employee is required to perform the duties. ...
Technical Interpretation - Internal

3 October 1997 Internal T.I. 9718927 - INFORMATION SLIPS - LABOUR-SPONSORED FUNDS TAX CREDIT

Pursuant to paragraph 204.81(6)(c) of the Act, the Minister may revoke the registration of a corporation where the corporation fails to issue to an individual before April of the following calendar year an information return in prescribed form (T5006) stating the amount of the consideration paid for the Class A share of the capital stock of the corporation the individual acquired or irrevocably subscribed and paid in the period beginning on the 61st day of a calendar year and ending on the 60th day of the following calendar year. ...
Technical Interpretation - External

8 October 1997 External T.I. 9722635 - FOREIGN PLAN, GERMAN PENSION

In your letter you outlined a number of factors for our consideration. ...
Ministerial Letter

8 October 1997 Ministerial Letter 9718888 - EDUCATION CREDIT "FULL-TIME STUDENT"

If the university determines that your status should be revised and provides you with certification to this effect, you may submit this documentation, along with a request for adjustment to your tax returns for the relevant taxation years, to your local tax services office for consideration. ...
Technical Interpretation - External

6 November 1997 External T.I. 9728755 - BENEFIT CONFERRED ON ISSUANCE OF SHARES

A exchanges his 20 preferred shares in Opco for no consideration other than 20 common shares in Opco pursuant to subsection 51(1) or 86(1) of the Act. ...
Technical Interpretation - External

12 December 1997 External T.I. 9642285 - LOSSES OF SUBSIDIARY ON WIND-UP

The comments expressed in this letter are of a general nature and do not take into account considerations that may arise in the context of a specific transaction. ...
Technical Interpretation - External

2 January 1998 External T.I. 9732155 - MORTGAGE POWER OF SALE

Details should be provided to the TSO for their consideration and referral to us should that be necessary. ...
Technical Interpretation - External

13 January 1998 External T.I. 9733375 - RETIRING ALLOWANCE PERSON RELATED TO EMPLOYER

Attention: XXXXXXXXXX January 13, 1998 Dear Sirs: Re: Retiring Allowance Your facsimile dated December 11, 1997 to Daniel Desjardins of the Individual Returns and Payments Processing Directorate has been forwarded to us for consideration and reply. ...
Technical Interpretation - External

3 December 1997 External T.I. 9720065 - CARRYING ON BUSINESS IN CANADA - BANK ACCOUNT

Whether or not a particular non-resident corporation is carrying on business in Canada is a question of fact and a determination can only be made after consideration of all the relevant facts. ...
Technical Interpretation - External

20 November 1997 External T.I. 9726145 F - SOCIETES ASSOCIEES

La détention des actions n'est pas le seul facteur pris en considération pour déterminer si deux sociétés sont associées. ...

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