Search - consideration

Filter by Type:

Results 11051 - 11060 of 28976 for consideration
Ruling

2002 Ruling 2002-0174333 - GIFTS BY WILL

Unlimited number of XXXXXXXXXX preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum, redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share).? Unlimited number of XXXXXXXXXX preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share).? Unlimited number of voting XXXXXXXXXX preferred shares (one vote per share), retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share), not entitled to any dividends.? ...
Technical Interpretation - External

4 February 2000 External T.I. 1999-0014245 - PHSP-ADMINISTRATOR PLANS FOR PROP.

., (a) an undertaking by one person (the proprietor), (b) to indemnify another person(the employee), (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ... In this regard, it must contain the following basic elements: (a) an undertaking by one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. As stated in interpretation letter #9904155, dated April 28, 1999, it is our view that a plan which consists of a contract between a proprietor and an administrator, under which the administrator agrees to reimburse the proprietor, his or her spouse and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...
Ruling

2000 Ruling 2000-0004183 - INTEREST EXPENSE CONSOLIDATION

Funded by share capital subscribed for by ACO, ECO purchased all outstanding shares of Old DCO for aggregate consideration of approximately $XXXXXXXXXX. ... In addition, these shares: f) will not be shares in respect of which any person or partnership will be obligated to effect an undertaking described in subsection 112(2.2); g) will not be part of a dividend rental arrangement as defined in subsection 248(1); h) will not be shares in respect of which: i) any person or partnership will be obligated to effect an undertaking described in paragraph 112(2.4)(a); or ii) the consideration for which the shares will be issued will not be or included any obligation described in subparagraph 112(2.4)(b)(i) or a right described in subparagraph 112(2.4)(b)(ii). 9. CCO will immediately advance the proceeds from the issuance of the preferred shares to DCO in consideration for an unsecured promissory note bearing interest at XXXXXXXXXX%. ...
Ruling

2000 Ruling 1999-0014333 - Wind Up of Partnership

H proposes to sell his interest in the Partnership, at a price equal to its fair market value, to the Company and in consideration therefor, the Company will issue to H a promissory note equal to such fair market value. ... On the day following the transaction described in 10 above, W proposes to sell her interest in the Partnership, at a price equal to its fair market value, to the Company and in consideration therefor, the Company will issue to W a promissory note equal to such fair market value. ... While H and W will own the Farmland, their intent is to rent it to other farmers for cash consideration or to sell it. 16. ...
Technical Interpretation - Internal

29 November 2000 Internal T.I. 2000-0051367 - INTEREST ON REDEMPTION OF SHARES

In summary, the situation under consideration is as follows: XXXXXXXXXX In your opinion, as a material portion of the judgrnent pertains to the redemption of capital, i.e. ... In the Income Tax Technical News # 3, the Agency's view on a promissory note issued as consideration for the redemption or purchase for cancellation of a corporation's capital stock is as follows: "It is the Department's view that the interest payable on a promissory note issued as consideration for the redemption or purchase for cancellation of a corporation's capital stock is not deductible under paragraph 20(1)(c). ...
Technical Interpretation - Internal

30 June 1989 Internal T.I. 57939 F - Purification of a Small Business Corporation

In consideration for the Transferred Opco Shares, Newco issues to Mr. ... (c)     Opco then sells to Newco the Non-Qualifying Assets at their fair market value of $200,000, and receives as consideration therefore redeemable preference shares of Newco with an aggregate redemption amount and fair market value of $200,000 and having nominal paid-up capital. ... has not identified a potential purchaser of the Opco Shares and he has no intention of selling the Opco Shares ("Situation 1"); (b)     at the time or the Reorganization, the sale of the Opco Shares is not under consideration or negotiation, although there are several potential purchasers in the marketplace and an offer could be received or negotiations commenced soon after the Reorganization ("Situation 2"); or (c)     at the time of the Reorganization Mr. ...
Administrative Letter

9 October 1990 Administrative Letter 901536 F - Cape Breton Investment Tax Credit

Conveyance of interest in property for specified period usually in consideration of rent,      a "lessee" as one who rents property from another. ... One who has use and occupation of real property of a landlord... the terms of this tenancy being fixed by a "lease", and      "rent" as consideration paid for use or occupation of any property, land, buildings, equipment, etc.            ... On the basis of the above dictionary definitions a lease arrangement for the purposes of the definition of "approved project property", could be considered, in our view, to include an arrangement between a landlord and a tenant which results in the use of real property for a specified period of time for consideration that is rent. 3.      ...
Miscellaneous severed letter

4 May 1990 Income Tax Severed Letter AC74844 - Investment Tax Credit for Qualified Exploration Expenditures - Review of Form T2038(Ind)

Could consideration be given to using wording similar to that used on form T2038 (Corp.) presented under the heading "Supplementary Information"? ... Could consideration be given to using a layout for page 3 that is similar to the layout used for corporations? ... Could consideration be given using the same format as is used for corporations? ...
Miscellaneous severed letter

30 June 1989 Income Tax Severed Letter 5-7939 - Purification of small business corporation

In consideration for the Transferred Opco Shares, Newco issues to Mr. ... (c) Opco then sells to Newco the Non-Qualifying Assets at their fair market value of $200,000, and receives as consideration there for redeemable preference shares of Newco with an aggregate redemption amount and fair market value of $200,000 and having nominal paid-up capital. ... X has not identified a potential purchaser of the Opco Shares and he has no intention of selling the Opco Shares ("Situation 1"); (b) at the time of the Reorganization, the sale of the Opco Shares is not under consideration or negotiation, although there are several potential purchasers in the marketplace and an offer could be received or negotiations commenced soon after the Reorganization ("Situation 2"); or (c) at the time of the Reorganization Mr. ...
Miscellaneous severed letter

4 May 1990 Income Tax Severed Letter RRRR272 - Review of Form T2038(IND)

Could consideration be given to using wording similar to that used on form T2038 (Corp.) presented under the heading "Supplementary Information". 5. ... Could consideration be given to using a layout for page 3 that is similar to the layout used for corporations? ... Could consideration be given using the same format as is used for corporations? ...

Pages