Search - consideration
Results 101 - 110 of 172 for consideration
Technical Interpretation - Internal summary
6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident -- summary under Subparagraph 115(1)(a)(i)
On January 1, 2009, the US employee was granted stock options by Canco in consideration for his duties of employment performed for USCo and, when the options were exercised, USCo paid Canco a sum equal to the in-the-money value of the options at the time of such exercise. ...
Technical Interpretation - Internal summary
29 January 2015 Internal T.I. 2014-0544651I7 - Section 85 transfer of Swap Contracts -- summary under Subsection 85(1)
We have also taken into consideration that the… property and values were accurately described. ...
Technical Interpretation - Internal summary
5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes -- summary under Subsection 105(1)
However, it should be taken into consideration that she has already been taxed on the income allocated to her by Trust. ...
Technical Interpretation - Internal summary
17 June 2013 Internal T.I. 2013-0475621I7 - PUC adjustment -- summary under Subsection 85(2.1)
17 June 2013 Internal T.I. 2013-0475621I7- PUC adjustment-- summary under Subsection 85(2.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(2.1) A non-resident corporation and another taxpayer transferred forward purchase agreements (FPAs) and promissory notes to a Canadian corporation in consideration for the issuance of common shares and jointly filed a T2057 election form. ...
Technical Interpretation - Internal summary
15 November 2013 Internal T.I. 2013-0478621I7 F - Transfer of intangibles - TP adjustments -- summary under Subsection 247(2)
CRA stated (TaxInterpretations translation) in indicating that a higher sale price should be imputed to Canco: [A]fter consideration of various provisions of the Act, such as section 68 and 69 as well as subsections 14(1), 56(2) and 247(8), it appears to us that the primary adjustments respecting Canco should, where appropriate, be through an application of subsection 247(2). ...
Technical Interpretation - Internal summary
15 December 2014 Internal T.I. 2014-0544121I7 F - Chantier particulier -- summary under Subsection 6(6)
Consideration should also be given, inter alia, to the possibility that the employment contract may be renewed and evidence of an intention to work there temporarily or otherwise. ...
Technical Interpretation - Internal summary
22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital -- summary under Eligible Capital Expenditure
CRA first noted that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value. ...
Technical Interpretation - Internal summary
30 March 2012 Internal T.I. 2011-0408311I7 F - Résidence principale -- summary under Ownership
X in consideration for a stipulated sum, and the transfer was duly registered in the land register of Quebec. ...
Technical Interpretation - Internal summary
30 March 2012 Internal T.I. 2011-0408311I7 F - Résidence principale -- summary under Paragraph (a)
X in consideration for a stipulated sum, and the transfer was duly registered in the land register of Quebec. ...
Technical Interpretation - Internal summary
22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution -- summary under Subsection 93(2.01)
Subsequently, the shares of Luxco2 were contributed as capital contribution by Canco to Luxco1 without share consideration, and Canco then sold the shares of Luxco1 to a third party, thereby realizing a capital loss. ...