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Technical Interpretation - Internal

18 March 2002 Internal T.I. 2001-0089547 - VOLUNTARY DISCLOSURE RCA

This request should be forwarded to the tax services office of the employer, for their consideration, in accordance with subsection 900(2) of the Regulations. ...
Ruling

2002 Ruling 2002-0122833 - STRUCTURED SETTLEMENT - USA

In consideration for the Assignee making such payments, the Claimant agrees to settle XXXXXXXXXX claims against the Defendants. 8. ...
Technical Interpretation - Internal

21 March 2002 Internal T.I. 2001-0113777 - M.K. Endowment Policy

., taking into consideration the deemed acquisition cost under subsection 128.1(1) of the Act) of that interest immediately before the disposition. ...
Technical Interpretation - External

14 May 2002 External T.I. 2001-0097785 - Deduction & Tax cr. on optional return

Your comments and our reply will be taken into consideration in the preparation of future versions of the Guide. ...
Ruling

2002 Ruling 2002-0134003 - FOREIGN PROPERTY DEBTS OF A TRUST

Vendor and Purchaser have entered into an asset purchase agreement (the "Agreement") whereby Vendor has agreed to sell the Special Asset to Purchaser for cash consideration. ...
Ruling

2002 Ruling 2001-009555A - Reversionary Trust - Non-Res Settlor

These rulings are based on the Act as it currently reads and do not take into consideration any proposed amendments thereto. ...
Technical Interpretation - Internal

11 September 2002 Internal T.I. 2002-0160977 - INDIAN BAND, XXXXXXXXXX

What are the considerations (e.g. capital vs. income)? Response The determination of whether payments under an XXXXXXXXXX would constitute capital or income payments or whether the payments would be taxable or exempt would require a review of all of the facts, including the terms of the particular agreement. ...
Technical Interpretation - External

7 November 2002 External T.I. 2002-0145125 - SPONSOR FEES GROUP RRSP

Similar considerations would have to be made in respect to expenditures made by an Employer in respect of an insured Group RRSP. ...
Ruling

2002 Ruling 2001-0112373 - TAX TREATMENT OF XXXXXXXXXX

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX, as described in more detail below: XXXXXXXXXX. 7. ...
Technical Interpretation - Internal

28 November 2002 Internal T.I. 2002-0164027 - CORPORATE LOAN FROM SHAREHOLDERS RRSP

Question #3: Is it reasonable for the interest rate on the loans to be set at an amount which does not take the guarantees into consideration? ...

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