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Technical Interpretation - External

22 March 1993 External T.I. 9302325 F - Deferred Salary Leave Program

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

17 March 1993 External T.I. 9238845 F - DSLP

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

9 July 1993 External T.I. 9303275 F - Wind-up of Corporation Owning Canadian Resource Property

., with reference to any agreements or other documentation concerning the winding-up under consideration. ... The determination of what other provisions of the Act may be relevant, e.g., anti-avoidance provisions such as subsections 69(11) or 245(2) of the Act, in a particular situation involving the winding-up of a corporation is also a question of fact which would have to be resolved based upon consideration of all of the facts relevant to that particular situation. ...
Technical Interpretation - External

7 July 1993 External T.I. 9306395 F - Loan to Purchase Principal Residence

A second consideration is not so apparent and concerns whether the loan was received by the individual in his capacity as a shareholder or an employee. ... In the case of the second consideration, it is the Department's view that where an individual, who is a shareholder and an employee of a corporation, receives a loan or becomes indebted to his or her corporation, there is a presumption that the loan has been received by the individual by virtue of being a shareholder rather than by virtue of being an employee. ...
Technical Interpretation - External

6 October 1993 External T.I. 9314355 F - Care and Maintenance Fund - Pre-need Assurance Fund

As exempting Pre-Need Assurance Funds from the application of subsection 104(4) of the Act would require an amendment to the existing legislation, we have brought this matter to the attention of the Department of Finance for their consideration. ... As an exemption from income tax for Care and Maintenance Funds that are not registered charities would require an amendment to the existing income tax legislation, we have brought this matter to the attention of the Department of Finance for their consideration. ...
Technical Interpretation - External

18 October 1993 External T.I. 9326565 F - HAA7680-4-2 DSLP

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

1 November 1993 External T.I. 9330995 F - Care and Maintenance Fund and Pre-need Assurance Trust

As exempting Pre-Need Assurance Funds from the application of subsection 104(4) of the Act would require an amendment to the existing legislation, we have brought this matter to the attention of the Department of Finance for their consideration. ... As an exemption from income tax for Care and Maintenance Funds that are not registered charities would require an amendment to the existing income tax legislation, we have brought this matter to the attention of the Department of Finance for their consideration. ...
Technical Interpretation - External

24 November 1993 External T.I. 9331185 F - HAA-7680-4-2 DSLP

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

24 April 1995 External T.I. 9427715 - SECURITIES LENDING

Usually, the borrower pays the lender a fee ("lending fee") in consideration for entering into the arrangement. ... Where the consideration given by the borrower for the shares consists of an obligation to return the shares that obligation would have a value equal to the fair market value of the shares transferred at the time the shares are acquired. ...
Technical Interpretation - External

11 April 1995 External T.I. 9503645 - DEFERRED SALARY LEAVE PLAN

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

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