Search - consideration
Results 2091 - 2100 of 2193 for consideration
Technical Interpretation - External
6 November 2002 External T.I. 2002-0149745 - 2002 CTF: Silicon Graphics (FCA)
., a U.S. public corporation, agreed to advance up to $5 million to Alias in consideration of a security interest in Alias' assets and the issuance of warrants to acquire common shares of Alias. ...
Technical Interpretation - External
22 January 2003 External T.I. 2002-0141415 F - BIENS UTILISES-ENTREPRISE
Toutefois, l'ADRC est disposé à prendre en considération tous les autres facteurs pertinents, incluant la valeur économique de la superficie occupée aux fins de l'exploitation d'une entreprise selon les circonstances particulières d'une situation donnée. ...
Technical Interpretation - External
6 February 2003 External T.I. 2002-0177105 - SUPERFICIAL LOSS V. CHILD
Generally speaking and as discussed in Interpretation Bulletin IT-405, Inadequate Considerations- Acquisitions and Dispositions, the rules address transactions that do not occur at fair market value and ensure, amongst other things, that the transferor of property does not artificially reduce the proceeds of disposition and the transferee does not inflate the cost of acquisition. ...
Technical Interpretation - External
6 February 2003 External T.I. 2002-0176895 F - Stock Options - Shareholder Benefit
Principal Issues: Whether, in a particular situation where a corporation ("USCO") grants to another corporation ("CANCO") options to purchase additional shares of USCO's capital stock and such options are not granted in consideration for services previously rendered, subsection 15(1) would apply to CANCO at the time of the granting of such options and/or at the time of their exercise. ...
Technical Interpretation - External
3 June 2003 External T.I. 2002-014675A - Computation interest on bonds/estate
The premium paid on the purchase of a bond is added to its ACB, and any amount deducted under ss. 20(14) of the Act reduces the ACB. (3) The owner of a strip bond is required to include the interest that accrued at the end of the anniversary day of the contract (ss. 12(4) of the Act) and that amount is included in the ACB of the bond (ss. 52(1) of the Act. (4) An estate may deduct the amounts payable to a beneficiary and the appropriate T3 or NR4 slips have to be issued. (5) Various considerations. ...
Technical Interpretation - External
7 November 2018 External T.I. 2018-0777361E5 - TOSI and dividend income, including from a trust
It is a question of fact as to whether the children would be considered to meet the excluded business test with consideration given to the nature, and the labour requirements of Investco’s business. ...
Technical Interpretation - External
6 January 2000 External T.I. 9926285 - PRINCIPAL RESIDENCE -FARM
At the time of transfer of a portion of the property to an adult child for no consideration, where the property has increased in value, a capital gain is determined and the provisions of subparagraph 69(1)(b)(ii) of the Act are applicable. ...
Technical Interpretation - External
20 March 2000 External T.I. 2000-0002565 - CANADA COUNCIL AWARDS
For instance, you indicate that the merit of the musician's proposed project is one of the considerations for receiving the award; however, it is unclear how much weight is allocated to this factor and which other factors are considered. ...
Technical Interpretation - External
10 April 2000 External T.I. 2000-0004715 - DEFERRED INCOME OF FARMERS-AUCTION SALE
While certain auctioneers may as a practical consideration defer payment to the vendor until such time as the purchaser's cheque has cleared, this does not change the position that the funds belong to the vendor as of the time the auctioneer has declared the livestock to be sold. ...
Technical Interpretation - External
20 October 2000 External T.I. 2000-0041725 - Film Tax Credit
This would entail consideration of the specific facts, including the identities of the parties and any non-arm's length relationships between any of them. ...