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Miscellaneous severed letter

14 September 1992 Income Tax Severed Letter 2M01980 - Income Earned or Realized

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information This example illustrates why losses of corporations in a corporate group must be included in the computation of consolidated income earned or realized.5 The same result would obtain if, sometime before the relevant time, A Co had sold the shares of C Co to B Co for nominal consideration. ... Investment Tax Credit Depreciable Property A corporation that has acquired a property, or made an expenditure, the specified percentage of which is included in its investment tax credit as defined in subsection 127(9) may claim a deduction from its tax otherwise payable under Part I of the Act as permitted in subsection 127(5), or it may be deemed by subsection 127.1(1) to have paid an amount on account of its tax under Part I of the Act, which amount is deemed to have been deducted under subsection 127(5). 1) Subsection 13(7.1) A incorporates A Co and subscribes for common shares for consideration of $100. ...
Technical Interpretation - Internal

5 June 1992 Internal T.I. 9129917 F - Banks' Securities Transactions - Income or Capital

Economic considerations dictated the sale in 1951. His Honour held that the profit on sale was made in the carrying on of the company's business and was assessable as a profit according to the ordinary usages and concepts of mankind. ... One important consideration in buying shares was that they should immediately- or within a reasonable period- produce a dividend yield of 4% or better. ...
Old website (cra-arc.gc.ca)

Direct Sellers

Supply for no consideration or nominal consideration, and appropriation for own use 34. ... Supply for no consideration or nominal consideration, and appropriation for own use 46. ... The consideration would be the service of hosting the event. Restrictions on ITCs. ...
Current CRA website

Direct Sellers

Supply for no consideration or nominal consideration, and appropriation for own use 34. ... Supply for no consideration or nominal consideration, and appropriation for own use 46. ... The consideration would be the service of hosting the event. Restrictions on ITCs. ...
Current CRA website

Direct Sellers

Supply for no consideration or nominal consideration, and appropriation for own use 34. ... Supply for no consideration or nominal consideration, and appropriation for own use 46. ... The consideration would be the service of hosting the event. Restrictions on ITCs. ...
Old website (cra-arc.gc.ca)

Section 232.1 - Promotional Allowances

Some allowances will continue to be regarded as consideration for a taxable supply or a reduction in consideration. ... The allowances are deemed not to be consideration for a supply. Example No. 2 Statement of Facts 1. ... The allowance is deemed not to be consideration for a supply. Date modified: 2004-06-02 ...
Old website (cra-arc.gc.ca)

Excise and GST/HST News No. 96

The student pays a single consideration for the meals provided under the meal plan. ... Although “single consideration” is not defined in the Act, the Act does define “consideration” to include any amount that is payable for a supply by operation of law. Where a student enters into an agreement for meals to be provided under a meal plan and the agreement specifies that there is a single consideration, but the payment for that consideration may be made on an instalment basis, the CRA accepts that this type of arrangement meets the requirement of “single consideration”. ...
Current CRA website

Excise and GST/HST News - No. 96

The student pays a single consideration for the meals provided under the meal plan. ... Although “single consideration” is not defined in the Act, the Act does define “consideration” to include any amount that is payable for a supply by operation of law. Where a student enters into an agreement for meals to be provided under a meal plan and the agreement specifies that there is a single consideration, but the payment for that consideration may be made on an instalment basis, the CRA accepts that this type of arrangement meets the requirement of “single consideration”. ...
Scraped CRA Website

Section 232.1 - Promotional Allowances

The supplier may choose to adjust the tax on the deemed reduction in consideration in accordance with subsection 232(2). ... Some allowances will continue to be regarded as consideration for a taxable supply or a reduction in consideration. ... The allowances are deemed not to be consideration for a supply. Example No. 2 Statement of Facts 1. ...
Current CRA website

Section 232.1 - Promotional Allowances

The supplier may choose to adjust the tax on the deemed reduction in consideration in accordance with subsection 232(2). ... Some allowances will continue to be regarded as consideration for a taxable supply or a reduction in consideration. ... The allowance is deemed not to be consideration for a supply. Page details Date modified: 2004-06-02 ...

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