Search - consideration
Results 8161 - 8170 of 13676 for consideration
Ruling
2008 Ruling 2008-0266221R3 - Loss utilization
The Preferred Shares will not be, at any time during the implementation of the Proposed Transactions described herein: i) the subject of any undertaking that is referred to in subsection 112(2.2) of the Act as a "guarantee agreement"; ii) the subject of a dividend rental arrangement as that term is defined in subsection 248(1) of the Act; iii) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; or iv) issued for consideration that is or includes: (A) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act, other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or (B) any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 31. ...
Ruling
2008 Ruling 2008-0269281R3 - Donation of flow-through shares
The Charities will direct the transfer agent to register the certificates for the Units in the name of the Liquidity Providers. 21) As consideration for having arranged the series of transactions, the Charities will pay a fee to the Promoter equal to XXXXXXXXXX % of the gross selling price of the Units sold to the Liquidity Providers. 22) You advise that none of the Charities has given any undertaking or is obliged in any way to sell the Units to the Liquidity Providers and none of the Liquidity Providers is under obligation or has a right to acquire the Units from the Charities. ...
Ruling
2008 Ruling 2008-0281941R3 - Donation of flow-through shares
The Charities will direct the transfer agent to register the certificates for the Shares in the name of the Liquidity Providers. 22) As consideration for having arranged the series of transactions, the Charities will pay a fee to the Promoter equal to XXXXXXXXXX % of the gross selling price of the Shares sold to the Liquidity Providers. 23) You advise that none of the Charities has given any undertaking or is obliged in any way to sell the Shares to the Liquidity Providers and none of the Liquidity Providers is under obligation or has a right to acquire the Shares from the Charities. ...
Technical Interpretation - Internal
13 August 2008 Internal T.I. 2008-0267061I7 - Application of Guideline 4
This is the key consideration, whether an organization has a formal board of directors, is managed by another group of persons, or is managed by one individual. ...
Ruling
2008 Ruling 2007-0259531R3 - Forgiveness of interest
This release would be given without any payment or other consideration being received or receivable from Acquireco in respect of such liabilities. ...
Miscellaneous severed letter
7 July 2008 Income Tax Severed Letter 2008-0288701R3 - Supplemental to ruling 2007-023750
Accordingly, the first three sentences in Paragraph 24 are changed to read as follows: Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting of XXXXXXXXXX DC New Common Share and XXXXXXXXXX DC Butterfly Share. ...
Ruling
2008 Ruling 2008-0289331R3 - Reduction of stated capital of public corporation
After careful consideration of the cash requirements of Pubco, Pubco determined that the cash remaining after the Distribution would be adequate to support any potential growth of Pubco. ...
Ruling
2016 Ruling 2015-0611061R3 - Loss Consolidation Arrangement
The subject of “dividend rental arrangement” as defined by subsection 248(1) with respect to any of the shares issued for the purposes of completing the Proposed Transactions; c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 19. ...
Technical Interpretation - External
20 February 2007 External T.I. 2006-0210291E5 F - Remboursement des billets d'avion
Raisons: 1) Afin de déterminer s'il y a un avantage imposable pour les employés, il faut prendre en considération la raison pour laquelle l'employeur rembourse ces frais et à qui bénéficie le plus de cet arrangement. 2) Position exprimée au paragraphe 15 du bulletin d'interprétation IT-470R(Consolidé), au paragraphe 8 du bulletin d'interprétation IT-131R et dans le guide de l'employeur T4130. 2006-021029 XXXXXXXXXX Anne Dagenais Avocate,M. ...
Conference
6 October 2006 Roundtable, 2006-0196001C6 F - Penalties and Statute Barred Years
X and their FMV, for example, without taking into consideration, amongst other things, the CRA's valuation principles, practices and policies in Information Circular 89-3, while a prudent and conscientious person exercising due diligence would have done it. ...