Search - consideration
Results 10321 - 10330 of 28958 for consideration
Miscellaneous severed letter
27 September 1993 Income Tax Severed Letter 9313975 - Gift of Residual Interest in Real Property
XXXXXXXXXX Rather than being a gift it might be a sale or transfer for consideration equal to the value of the lease, notwithstanding the fact that the fair market value far exceeds the consideration. ...
Miscellaneous severed letter
6 October 1993 Income Tax Severed Letter 932697A F - Gift
The charity would issue a receipt to the Client for the full retail value of the prints, being approximately $XXXXXXXXXX The Client will receive no other consideration for his donation. ... The determination as to whether a specific donation of prints to a registered charity would constitute a voluntary transfer of property without consideration must be made on the basis of the facts in each particular case. 3. ...
Technical Interpretation - External
26 October 1993 External T.I. 9329005 F - 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. ...
Technical Interpretation - External
17 March 1994 External T.I. 9334025 - ATTRIBUTION OF INCOME
In a subsequent year, the taxpayer transferred shares of a corporation to his spouse for fair market consideration which was in excess of the adjusted cost base of the shares. This consideration consisted of a demand promissory note bearing interest at the prescribed rate. ...
Technical Interpretation - External
8 March 1995 External T.I. 9433255 - CURTESY ELECTION - WHETHER A TRUST
Such a determination would require a full consideration of all facts and surrounding circumstances. ... We offer the following general comments for your consideration. The characteristics of a trust are described by D.W.M. ...
Technical Interpretation - External
28 July 1995 External T.I. 9509475 - MEDICAL EXPENSES AND CHARITABLE DONATIONS
In paragraph 3 of IT-110R2 it states that "A gift, for purposes of sections 110.1 and 118.1, is a voluntary transfer of property without valuable consideration." ... Consideration of changes to existing legislation is the responsibility of the Department of Finance. ...
Technical Interpretation - External
14 December 1995 External T.I. 9529255 - INTERNATIONAL SHIPPING-GAIN FROM DISPOSITION OF GOODWILL
It is our view that an amount received by a non-resident corporation in respect of goodwill on the disposition of a business which earns income described in paragraph 81(1)(c) of the Act would not be included in income under paragraph 14(1)(b) of the Act as the consideration received by the non-resident corporation in respect of the disposition is not included under paragraph E(a) of the definition of "cumulative eligible capital" in subsection 14(5) of the Act. This is so because had the consideration given by the non-resident corporation (i.e. the goodwill) been paid for by the non-resident corporation, the payment would not have been an "eligible capital expenditure" also as defined in subsection 14(5) of the Act, as it would have been incurred for the purpose of gaining or producing income that is exempt income. ...
Technical Interpretation - External
13 February 1996 External T.I. 9602915 - CAREGIVERS AND EXEMPT INCOME
The consideration of whether or not the payments are non-taxable involves paragraph 81(1)(h) of the Act. ... In determining whether or not payments received by a caregiver are non-taxable by virtue of paragraph 81(1)(h) of the Act, an important consideration is whether the caregiver is an employee or an independent contractor. ...
Technical Interpretation - Internal
17 April 2003 Internal T.I. 2003-0013427 - PROPOSED GIFTING LEG.-MULTIPLE GIFTS
Another case we have been asked to consider is the situation where a donor is provided with an article (advantage) in consideration for a pledge to make donations over a number of years. ... If you encounter such a situation, we recommend that the case be referred to Rulings for further consideration. ...
Technical Interpretation - External
24 April 2003 External T.I. 2003-0008355 - Foreign investment entity rule
The units of the Trust are issued to the unitholders in consideration of Canadian funds payable to the Trust. 3. ... The Agreement provides that the Trust agrees to make a cash payment in Canadian funds to the Canadian bank in consideration for the right to exercise against the Canadian bank an option ("option right") to obtain from the Canadian bank a pre-determined percentage of the fair market value of an investment basket that both parties have agreed upon at closing. 4. ...