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Ruling

2006 Ruling 2005-0142471R3 - Amalgamation of NPOs

Under this contract, substantial consideration based on a fee per member of NPO1 was to be paid by NPO1 to the Plaintiff for several years. ...
Technical Interpretation - External

28 June 2006 External T.I. 2006-0172111E5 - ABIL

Under subparagraph 40(2)(g)(ii) of the Act, a taxpayer's loss arising from the disposition of a debt is nil (and therefore cannot result in a capital loss) unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...
Technical Interpretation - External

9 August 2006 External T.I. 2005-0163621E5 - Subparagraph 84.1(2)(a.1)(ii) and Section 110.6

A would also like to take back non-share consideration on this transfer to the maximum extent possible without being deemed to have received a dividend pursuant to paragraph 84.1(1)(b). ...
Ruling

2006 Ruling 2006-0201601R3 - Whether a bonus is reasonable in the circumstances

Pursuant to an Agreement of Purchase and Sale between the Corporation and XXXXXXXXXX (the "Purchaser"), a division of XXXXXXXXXX, a sale of the Assets (the "Sale of Assets") was made by the Corporation to the Purchaser, effective XXXXXXXXXX, for consideration of $XXXXXXXXXX. ...
Ruling

2006 Ruling 2006-0173771R3 - Ceasing to be an Insurance Corporation

As consideration for Newco assuming the obligations under the Assumed Contracts from the Taxpayer, the Taxpayer will pay an amount equal to the present value of those obligations to Newco in cash and the Taxpayer will assign all of its rights under those contracts to Newco. 17. ...
Conference

6 October 2006 Roundtable, 2006-0196231C6 F - 75(2) - Fiducie

In order to clarify the CRA's position, and taking into consideration the new facts outlined above: (i) Will subsection 75(2) ITA apply to the income, losses, taxable capital gains and deductible capital losses derived by Trust X from Corporation Y's shares so as to allocate these amounts to Corporation Y? ...
Ruling

2006 Ruling 2006-0198111R3 F - Intérêt exonéré d'impôt - alinéa 81(1)a)

Société A a émis le XXXXXXXXXX à des Indiens résidant sur une réserve ou ailleurs des obligations pour un montant total de XXXXXXXXXX $ en contrepartie d'une considération globale de XXXXXXXXXX $. ...
Technical Interpretation - Internal

15 February 2007 Internal T.I. 2006-0193891I7 - Transfer of Tuition Tax Credits to Brother

In Canadian jurisprudence relating to the Act, the concept of de facto adoption has received consideration. ...
Ruling

2006 Ruling 2006-0202071R3 - Definition of "corporation" in subsection 248(1).

As consideration for the equity interest in the Joint Venture transferred to it by Canco, Newco will issue additional shares to Canco. ...
Ruling

2007 Ruling 2006-0211191R3 - Flexible Employee Benefit Program

After extensive negotiations, a new compensation plan was developed that resulted in the discontinuance of the banking and accrual of SDO's effective XXXXXXXXXX, and in consideration for which the Council approved a general wage increase of XXXXXXXXXX% for all Employees. 23. ...

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