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Ruling

30 November 1995 Ruling 9611983 - APPLICABILITY OF WITHOLDING EXEMPTION UPON WINDING UP

Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...
Technical Interpretation - External

7 March 1997 External T.I. 9621945 - STATUS AS A NRO

Other considerations would include the implications of subsection 18(4) of the Act with respect the interest deduction being claimed by Opco. ...
Ruling

30 November 1995 Ruling 9625113 - TRANSFER OF FARM PROPERTY

XXXXXXXXXX and Holdco, and XXXXXXXXXX and Holdco, will jointly elect, within the time and in the manner prescribed by subsection 85(6), to effect the transfer of XXXXXXXXXX under section 85 at an agreed amount equal to the adjusted cost base of their respective interests in XXXXXXXXXX, plus an amount equal to that which can be sheltered by their respective remaining lifetime capital gains exemptions for qualified farm property, up to the fair market value of XXXXXXXXXX. 13.As consideration for XXXXXXXXXX, Holdco will issue a non-interest-bearing promissory note to each of XXXXXXXXXX having a principal amount equal to the agreed amount, and will issue redeemable retractable preferred shares in its capital stock to each of XXXXXXXXXX having a redemption amount and fair market value equal to the difference between the fair market value of XXXXXXXXXX and the principal amount of the promissory note. ...
Ruling

30 November 1995 Ruling 9631383 - STRUCTURED SETTLEMENTS

In consideration of the Insurer making such payments, the Claimants settle their claim against the Insurer. ...
Technical Interpretation - External

23 July 1997 External T.I. 9639765 - TIMBER LIMITS

If your enquiry relates to proposed transactions, we would be pleased to give further consideration to these issues in the context of an advance income tax ruling request, where all relevant, facts, documentation and other relevant information are available and those facts can reasonably be expected to prevail. ...
Technical Interpretation - Internal

5 June 1997 Internal T.I. 9704727 - SPECIAL WARRANT ISSUE COSTS

Usually no additional consideration is payable on the exercise of the Special Warrants. ...
Technical Interpretation - External

8 May 1997 External T.I. 9707165 - REPORTING FOR EMPLOYEES

Many factors must be taken into consideration in establishing whether an individual is an employee or is self-employed. ...
Technical Interpretation - Internal

23 June 1997 Internal T.I. 9712046 - SUBSECTION 227(6.1) AND ARTICLE X OF U.S. TREATY

The second amount would, therefore, take into consideration the tax rate at the time the loan was repaid. ...
Ruling

30 November 1996 Ruling 9714603 - STRUCTURED SETTLEMENTS

In consideration of Insurers A and B making such payments, the Claimant settles the claim against the Defendants. ...
Technical Interpretation - External

28 July 1997 External T.I. 9717505 - RETIRING ALLOWANCES

Consideration may also be given to the payment of amounts that fall outside of these limitations if the amounts can be considered reasonable in the circumstances. ...

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