Search - consideration
Results 2221 - 2230 of 2272 for consideration
Miscellaneous severed letter
1998 Income Tax Severed Letter 980551B - CANADIAN FILM OR VIDEO PRODUCTION TAX CREDIT
Creditco's consideration for the providing of its services will be the $XXXXXXXXXX of Tax Credits, plus a fee of $XXXXXXXXXX from THC. 10. ... The consideration payable by THC to the Production Partnership in respect of the production services will be a fixed amount (the "XXXXXXXXXX% Fee") equal to XXXXXXXXXX% of the amount of the production expenses of the Production Partnership payable upon satisfactory completion of the production services (generally upon completion and delivery of the Film). ...
Miscellaneous severed letter
24 February 1992 Income Tax Severed Letter 9206085 - 1992 Manitoba Canadian Bar Association/CICA Roundtable
Consideration will be given to allow subsection 153(1.1) reductions for more than one year, if the original circumstances supporting the reduction continues in future years. ... Department's Position (a) Whether bona fide arrangements are made for the repayment of a housing loan within a reasonable period of time at the time the loan is made is a question of fact which can only be determined upon consideration of all the circumstances of a particular situation. ...
Miscellaneous severed letter
7 July 2008 Income Tax Severed Letter 2008-0288701R3 - Supplemental to ruling 2007-023750
Accordingly, the first three sentences in Paragraph 24 are changed to read as follows: Each Participant will exchange each of the Participant's DC Common Shares for consideration consisting of XXXXXXXXXX DC New Common Share and XXXXXXXXXX DC Butterfly Share. ...
Miscellaneous severed letter
16 August 1993 Income Tax Severed Letter 9309747 - Asbestos Removal Costs
We assume that the auditor's report contains a statement indicating that the income was computed in accordance with GAAP for the four years now under consideration. ...
Miscellaneous severed letter
10 March 2000 Income Tax Severed Letter 2000-0012136 - INDIAN TAXATION
While it may carry some weight, the most important considerations are the location of the revenue-generating activities, and the location of the customers of the business. ...
Miscellaneous severed letter
27 March 1990 Income Tax Severed Letter AC74543 - Non-resident Withholding Tax on Indemnity Payments
"it may well be on a subsequent occasion both the reasoning in Holder's case and the distinction drawn between that case and the present by Lord Denning MR may deserve further consideration." ...
Miscellaneous severed letter
7 June 1990 Income Tax Severed Letter AC74735 F - Exonération de gains en capital - Suffisance de dividendes
Si la corporation n'a pas versé de dividende (ou a verse un dividende inférieur a 90, du taux de rendement annuel moyen) parce qu'elle a réinvesti ses surplus dans son entreprise exploitée activement, de manière à accroître la valeur des àctions, nous sommes d'avis que ce fait pourrait être pris en considération pour établir si cette condition est respectée. ...
Miscellaneous severed letter
18 April 1990 Income Tax Severed Letter 5-9647 - Request for Technical Interpretation—paragraph 66(15)(c) of the Income Tax Act—treatment of a payment made to purchase or cancel a royalty interest
Given that the royalty interest qualifies as a Canadian resource property under subparagraph 66(15)(c)(v) of the Act, there seems little doubt that Company A has "acquired" a property in consideration for its payment to Company B. ...
Miscellaneous severed letter
7 October 1996 Income Tax Severed Letter 9608645 - Timing of revenue
Accordingly, we are unable to comment substantively, with respect to the timing of matching these outlays, against the recovery of ESCO's share of anticipated savings, other than to say that GAAP would be appropriate, taking into consideration that the costs for equipment could represent capital expenditures made on behalf of the client rather than an expense incurred to produce revenue containing a profit element. ...
Miscellaneous severed letter
24 September 1996 Income Tax Severed Letter 9616347 - Meals and allowances
" The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...