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Miscellaneous severed letter

21 June 1991 Income Tax Severed Letter 910822 - At-Risk Rules

The limited partner pays a reasonable guarantee fee to the partnership as consideration, as well as provides an indemnity saving the partnership harmless from any loss or cost it may suffer as a result of the guarantee. ...
Miscellaneous severed letter

30 October 1986 Income Tax Severed Letter 5-1782

BV is resident in the Netherlands and taking into consideration your analysis it would appear that the Dutch guilder is the currency that should be used to determine any gain or loss on the disposition of the shares of NV. ...
Miscellaneous severed letter

4 December 1992 Income Tax Severed Letter 9219615 - Capital Gains - Significant Amount

Nevertheless, to determine whether it applies, consideration must be given to the fact that dividends were not paid on shares in preceding taxation years, other than prescribed shares. ...
Miscellaneous severed letter

10 March 1992 Income Tax Severed Letter 9202905 - Non-profit Organization - 24(1)

Questions relating to tax considerations of a particular taxpayer should be addressed to your local District Taxation Office. ...
Miscellaneous severed letter

30 June 1986 Income Tax Severed Letter RCT 5-0259 F

MCo will purchase for cancellation its common shares held by Newco at their fair market value for consideration which will include cash and a promissory note. ...
Miscellaneous severed letter

14 August 1981 Income Tax Severed Letter RCT 5-2662 F

Among other factors we would consider are the following: the purpose of the transaction, the type of property transferred on a tax-deferred basis, the type of gain that would be realized on a sale at fair market value, whether the subsequent disposition of the shares received in consideration of the transfer was contemplated at the time of the transfer, and whether the purpose of the rollover was to facilitate a conversion of ordinary income into a capital gain. ...
Miscellaneous severed letter

8 April 1980 Income Tax Severed Letter 5-1397 - Foreign partnership

As consideration for the sale, mortgages were taken back by the partnership. ...
Miscellaneous severed letter

18 April 1990 Income Tax Severed Letter 5-9665 - Technical interpretation of paragraph 55(3)(b)

If, as part of the transactions, an amount is paid by the particular corporation to another corporation in consideration for that corporation assuming the obligations under the "take-or-pay" contract, the requirements of subsection 20(24) of the Act will not be satisfied since the particular corporation would not have included in its income the amounts previously received under that contract. ...
Technical Interpretation - Internal

15 February 2022 Internal T.I. 2020-0870731I7 - CEWS-qualifying rev in respect of a joint venture

Qualifying revenue of an eligible entity for a prior reference period or a current reference period, is defined in subsection 125.7(1) of the Act to mean the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity in Canada in the particular period, subject to certain inclusions or exclusions. ...
Technical Interpretation - External

16 March 2022 External T.I. 2019-0834191E5 - Travel Allowances

A further consideration is whether a Member of a Legislative Assembly who performs duties related to a Legislative Assembly in the City is travelling to perform the duties of employment. ...

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