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Ministerial Correspondence

25 August 2020 Ministerial Correspondence 2020-0854171M4 - Canada caregiver credit & spousal income

Therefore, I am sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...
Ministerial Correspondence

18 October 1989 Ministerial Correspondence 58074 F - Foreign Accrual Property Income and Currency Swaps

Should you wish to request an advance income tax ruling in respect of a particular proposed transaction, we would be pleased to give further consideration to such foreign exchange hedging arrangements. ...
Ministerial Correspondence

21 August 1989 Ministerial Correspondence 89M08094 F - Capital Dividend Account

Specifically, you have referred the following example for our consideration: A corporation, whose fiscal year end is September 30, has been carrying on business since before January 1, 1972. ...
Ministerial Correspondence

17 October 1990 Ministerial Correspondence 901534 F - Transfer of Retiring Allowances

Opco is under an obligation to pay its employees retiring allowances in certain circumstances in consideration of long-term services rendered to the company. 2.      ...
Ministerial Correspondence

25 September 1990 Ministerial Correspondence 74724 F - Privileges and Immunities of International Organizations

We do not have sufficient information concerning the staff retirement funds or the circumstances under consideration by you in connection therewith to comment definitively as to the proper tax treatment thereof. ...
Ministerial Correspondence

23 July 1990 Ministerial Correspondence 901034 F - Option to Acquire Shares

That is, any consideration received  for the granting of the option is a capital gain to the      individual. 2)        It is our view that the tax consequences of the subsequent repurchase by the individual who initially granted the option should be governed by paragraph 3 ofInterpretation bulletin IT-403R which states that "where the grantor of  any option purchases it back from the grantee and they are dealing at arm's length, the Department takes the position that the adjusted cost base of the property to the grantor is generally increased by the amount of the purchase price of the option from the grantee... ...
Ministerial Correspondence

13 June 1991 Ministerial Correspondence 910124 F - Flexible Benefit Plan

Furthermore, as discussed in Interpretation Bulletin IT-339R2, a PHSP must contain the following basic elements: 1)  an undertaking of one person, 2)  to indemnify another person, 3)  for an agreed consideration, 4)  from a loss or liability in respect of an event, 5) the happening of which is uncertain. ...
Ministerial Correspondence

27 April 1990 Ministerial Correspondence 58514 F - Reimbursement of Automobile Expenses

Although an allowance based on the 31 cents/25 cents per kilometre rate specified in draft Regulation 7305 may be considered reasonable in many situations, it is our view that the actual costs incurred by an employee should be taken into consideration in determining what would be a reasonable rate for the allowance. ...
Ministerial Correspondence

21 March 1990 Ministerial Correspondence 74664 F - Pension Payments

Perhaps you could ask 19(1) to provide us with all relevant information in such cases for our consideration.  ...
Ministerial Correspondence

11 January 1990 Ministerial Correspondence 74594 - Versions française du guide pensions et REER

Nous vous soumettons ces derniers commentaires pour votre considération. ...

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