Search - consideration

Results 7661 - 7670 of 13676 for consideration
Ruling

2006 Ruling 2006-0168701R3 - sale of assets; shareholder/key employee bonuses

The purchase price will be approximately $XXXXXXXXXX, with the consideration of cash in the amount of approximately $XXXXXXXXXX and units of the Limited Partnership having a fair market value of approximately $XXXXXXXXXX. 10. ...
Technical Interpretation - External

23 May 2006 External T.I. 2004-0107751E5 - Income recognition -income Trust Beneficiary

Your letter presented the following example for our consideration: Income Trust ABC distributes $1.00 per unit held ($.60 per unit is Other Income and $.40 is Return of Capital). ...
Technical Interpretation - External

16 June 2006 External T.I. 2004-0100621E5 - Application of s. 164(6) in a civil law context

A provides sufficient powers to the liquidator of the succession to have the corporation which issued the Shares redeem all or part of them and to effect a transfer of the Shares to another corporation in consideration for shares of the other corporation (the "Substituted Shares"). ...
Ruling

2006 Ruling 2006-0179471R3 - Utilization of Losses within an affiliated group

Profitco will acquire the all the issued and outstanding shares of Lossco from Forco1 for consideration equal to their estimated fair market value. ...
Conference

9 May 2006 Roundtable, 2006-0174121C6 - CALU 2006 Conference Questions and Answers

These elements, which are listed in paragraph 3 of IT-339R2, are the following: (a) an undertaking by 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. ...
Ruling

2006 Ruling 2005-0142471R3 - Amalgamation of NPOs

Under this contract, substantial consideration based on a fee per member of NPO1 was to be paid by NPO1 to the Plaintiff for several years. ...
Technical Interpretation - External

28 June 2006 External T.I. 2006-0172111E5 - ABIL

Under subparagraph 40(2)(g)(ii) of the Act, a taxpayer's loss arising from the disposition of a debt is nil (and therefore cannot result in a capital loss) unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...
Technical Interpretation - External

9 August 2006 External T.I. 2005-0163621E5 - Subparagraph 84.1(2)(a.1)(ii) and Section 110.6

A would also like to take back non-share consideration on this transfer to the maximum extent possible without being deemed to have received a dividend pursuant to paragraph 84.1(1)(b). ...
Ruling

2006 Ruling 2006-0201601R3 - Whether a bonus is reasonable in the circumstances

Pursuant to an Agreement of Purchase and Sale between the Corporation and XXXXXXXXXX (the "Purchaser"), a division of XXXXXXXXXX, a sale of the Assets (the "Sale of Assets") was made by the Corporation to the Purchaser, effective XXXXXXXXXX, for consideration of $XXXXXXXXXX. ...
Ruling

2006 Ruling 2006-0173771R3 - Ceasing to be an Insurance Corporation

As consideration for Newco assuming the obligations under the Assumed Contracts from the Taxpayer, the Taxpayer will pay an amount equal to the present value of those obligations to Newco in cash and the Taxpayer will assign all of its rights under those contracts to Newco. 17. ...

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