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Ruling

2007 Ruling 2007-0237921R3 - Thin capitalization

The Partnership and Bsub 2 will each subscribe, in the same number and amount, for additional Topco Class B shares for cash consideration. 11. ...
Technical Interpretation - Internal

25 February 2008 Internal T.I. 2007-0243871I7 F - Avantages imposables

En terminant, veuillez prendre en considération que le paragraphe 246(1) est une disposition d'application subsidiaire puisqu'il doit être démontré que la valeur de l'avantage n'est pas par ailleurs incluse (par exemple, en vertu du paragraphe 6(1)a)) dans le calcul du revenu du contribuable en vertu de la partie I de la LIR. ...
Ruling

2007 Ruling 2007-0228701R3 - life insurance and eligible funeral arrangements

In the case under consideration in this ruling, no arrangement for funeral services was to be made at the time of the purchase of the policy, the policy was not established and maintained by a qualifying person, nor was the policy acquired with the contribution to be held in trust or by a qualifying person as required by subsection 148.1(1). ...
Ruling

2006 Ruling 2006-0168751R3 - sale of assets; shareholder/key employee bonuses

The purchase price will be approximately $XXXXXXXXXX, with the consideration of cash in the amount of approximately $XXXXXXXXXX and units of Limited Partnership having a fair market value of approximately $XXXXXXXXXX. 13. ...
Ruling

2006 Ruling 2005-0126281R3 - Taxation of Employment Income of a Status Indian

This agreement between the parties includes commitments from the Company regarding training and education, employment and business opportunities, environmental management, social and cultural issues and financial compensation in consideration of First Nation support for the Project; (k) "Indian Act" means the Indian Act, R.S.C. 1985, c. ...
Ruling

2006 Ruling 2006-0168701R3 - sale of assets; shareholder/key employee bonuses

The purchase price will be approximately $XXXXXXXXXX, with the consideration of cash in the amount of approximately $XXXXXXXXXX and units of the Limited Partnership having a fair market value of approximately $XXXXXXXXXX. 10. ...
Technical Interpretation - External

23 May 2006 External T.I. 2004-0107751E5 - Income recognition -income Trust Beneficiary

Your letter presented the following example for our consideration: Income Trust ABC distributes $1.00 per unit held ($.60 per unit is Other Income and $.40 is Return of Capital). ...
Technical Interpretation - External

16 June 2006 External T.I. 2004-0100621E5 - Application of s. 164(6) in a civil law context

A provides sufficient powers to the liquidator of the succession to have the corporation which issued the Shares redeem all or part of them and to effect a transfer of the Shares to another corporation in consideration for shares of the other corporation (the "Substituted Shares"). ...
Ruling

2006 Ruling 2006-0179471R3 - Utilization of Losses within an affiliated group

Profitco will acquire the all the issued and outstanding shares of Lossco from Forco1 for consideration equal to their estimated fair market value. ...
Conference

9 May 2006 Roundtable, 2006-0174121C6 - CALU 2006 Conference Questions and Answers

These elements, which are listed in paragraph 3 of IT-339R2, are the following: (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. ...

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