Search - consideration

Results 22931 - 22940 of 29012 for consideration

12 August 2003 Internal T.I. 2003-0029717 - Stock Dividends

By XXXXXXXXXX, Gco had subscribed for XXXXXXXXXX Common Shares of Aco for aggregate consideration of $XXXXXXXXXX. ...

8 August 2003 Internal T.I. 2003-0025837 - EXCHANGEABLE SHARES DEBT FORGIVENESS

" "(2) Application of debt forgiveness rules- For the purposes of this section, (a) [when obligation settled]- an obligation issued by a debtor is settled at any time where the obligation is settled or extinguished at that time (otherwise than by way of a bequest or inheritance or as consideration for the issue of a share described in paragraph (b) of the definition "excluded security" in subsection (1)); Meaning of "settled or extinguished" The terms "settled" and "extinguished" are not defined in the Act, but the meaning of these terms was considered in the following case law: Central City Financial Services Ltd. v. ...

28 July 2003 Internal T.I. 2003-0013677 - Capital Distribution by a Non-resident Trust

Again, clause XXXXXXXXXX of the trust deed authorizes the trustee to make distributions of capital or distributions of income to the beneficiary in such amounts as the trustee, in its absolute discretion decides, subject only to clause XXXXXXXXXX and clause XXXXXXXXXX of the trust deed (which are not relevant to the issue under consideration). ...

2003 Ruling 2003-0003513 F - ORGANISME SANS BUT LUCRATIF

La cession est consentie en considération d'une somme d'environ XXXXXXXXXX $. 15. ...

11 December 2003 External T.I. 2003-0015975 F - calcul du gain/perte sur disposition

Principales Questions: Est-ce qu'un montant qu'un contribuable s'est engagé à verser suite à la disposition de ses actions peut être pris en considération dans le calcul du gain/perte relatif à ces actions, à titre de "dépenses engagées ou effectuées en vue de réaliser la disposition"? ...

2003 Ruling 2003-0041823 - FOREIGN PROPERTY PENSION CORPORATIONS

In connection with the initial organization of the Pension Corporation, the Corporation will subscribe for common shares of the Pension Corporation in consideration for cash and/or the transfer of certain (but not all) assets currently owned directly by the Corporation. ...

17 December 2003 Internal T.I. 2003-0047727 F - Right of Use-Deemed Trust

Principal Issues: In a given fact situation, an individual would dispose of a home used primarily for her personal use or enjoyment in favour of a corporation ultimately controlled by her sister ("X"), for fair market value consideration. ...

2003 Ruling 2003-0028343 - INDIAN BAND AS PUBLIC BODY

Neither are we confirming that the rent payable under the Lease represents fair market value consideration for the leasing of the Facility. ...

2003 Ruling 2003-0042493 - RRSP ACB OF FOREIGN PROPERTIES

As consideration for the redemption of its units, Fund 1 will become obligated to transfer to the RRSP, cash or property in an amount equal to the sum of the FMV of each unit redeemed ("Proceeds"). 21. ...

20 February 2004 Internal T.I. 2003-0054061I7 - Management Fees

The Agreement indicates that in consideration for the management services, Opco "shall pay to [Holdco] a management fee per annum equal to the total of (i) XXXXXXXXXX% of the net merchandise sales of [Opco], before taxes; and (ii) out-of-pocket costs and expenses incurred by [Holdco] from time to time in providing the services herein contemplated other than the costs and expenses incurred by [Holdco] in providing the services of [Mr. ...

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