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Conference

25 November 2021 CTF Roundtable Q. 8, 2021-0911881C6 - ss 15(2) and FA rules

Position: This question was sent to the Department of Finance for their consideration. ...
Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter 154

An organization's status for purposes of paragraph 149(1)(l) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...
Miscellaneous severed letter

7 June 1989 Income Tax Severed Letter 12

A CHANGE IN USE, IF ANY, PRIOR TO THE BUTTERFLY REORGANIZATION WOULD ALSO BE TAKEN INTO CONSIDERATION IN MAKING SUCH A DETERMINATION. ...
Miscellaneous severed letter

7 August 1990 Income Tax Severed Letter

In this situation, the payer corporation has provided valuable consideration with no reasonable expectation of repayment. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Gifts to a municipality

IN GENERAL, A GIFT IS A VOLUNTARY TRANSFER OF PROPERTY WITHOUT CONSIDERATION. ...
Miscellaneous severed letter

22 May 1990 Income Tax Severed Letter RRRR258 - Remission of tax

Shultis, a remission of branch tax in this case involves considerations of tax policy and would have to be sponsored by the Department of Finance. ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Forgiven interest — timing of the application of paragraph 80(1)(b) and subsection 20(16)

Consequently at the end of the taxation year on XXX the taxpayer, in computing the amount of the terminal loss which may be deducted for the year, must take into consideration the amount of the XXX capital cost reduction under paragraph 80(1)(b). ...
Miscellaneous severed letter

7 March 1991 Income Tax Severed Letter - Deductibility of right of way and easement costs

However, we have the following suggestions for your consideration to modify the report: 1. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Power-operated lifts for disabled individuals

Notwithstanding the above comments, we will forward a copy of your memorandum and our response to the Department of Finance for their consideration from a policy viewpoint. ...
Miscellaneous severed letter

11 June 1992 Income Tax Severed Letter - Assumption of debt

SUBJECT: ASSUMPTION OF DEBT SECTION: 20(1)(c)] 1992 Corporate Management Tax Conference INTEREST EXPENSE- ASSUMPTION OF VENDOR'S DEBT Question 3 Is it the Department's view that paragraph 20(1)(c) would allow a taxpayer to deduct interest paid on third party debt which the taxpayer has assumed as partial consideration for property acquired? ...

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