Search - consideration

Parmi les éléments à considérer, le fait que le même privilège soit accordé à des employés de la société qui ne sont pas des actionnaires, constituerait un facteur important, même s'il n'est pas le seul pris en considération. ...

The Corporation received $XXXXXXXXXX (hereafter referred to as the "Proceeds") from the Purchaser in consideration for the sale. ...

De plus, nous pouvons considérer la définition suivante qu'attribue le Shorter Oxford English Dictionary au terme " pension ": "an annuity or other periodical payment made, esp. by a government, a company or an employer of labour, in consideration of past services... ...

You argue that it is against the very nature of tax treaties for Canada to insist that a taxpayer file in accordance with the Convention where that results in double taxation, especially where the Article under consideration is the Article for the "Elimination of Double Taxation". ...

(f) In determining the prevailing commercial arm's length interest rate applicable to a loan that is similar to the Loan, could consideration be given to the likelihood of payments of Additional Interest never being made by the Borrower (i.e. the likelihood that the Borrower would never have Excess Cash available)? ...

Paragraph (b) of the definition of CCPC provides notably for the situation where a corporation would be controlled by a particular person, if each share of the capital stock of the corporation that is owned by a non-resident person were owned by the particular person. a) De Jure Control and Option Holding For the purposes of this definition, we must also take into consideration the options held by a person because of paragraph 251(5)(b) I.T.A. ...

To the best of your knowledge and that of the Partnership, Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico, none of the issues involved in this ruling is: (a) relevant to a tax return previously filed by Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (b) under consideration by a tax services office or taxation centre in connection with a previously filed tax return of Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (c) under objection by Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; (d) the subject of a ruling previously issued by this Directorate to the Partnership, Aco, Bco, Cco, Dco, Eco, Fco, Gco, Hco and Ico or a related person; or (e) before the courts or if a judgment has been issued, the time for an appeal to a higher court has not expired. ...

In consideration of granting the Canadian License, Can Production Co will receive from UK Co. #1 a lump sum amount of approximately $XXXXXXXXXX, which is approximately XXXXXXXXXX% of Can Production Co's costs of production (the "Initial Amount") and a lump sum payment of $XXXXXXXXXX (the "Additional Payment") to be made on the fifteenth anniversary of the completion date (the "Completion Date") of the sale/leaseback transaction in paragraph 12 below, provided that the Series has generated gross receipts (excluding VAT and any equivalent taxes) of $XXXXXXXXXX (excluding presales) and net of any commissions and other costs of distribution (the "Gross Receipts"). ...

The Situation In summary, the situation under consideration, as we understand it, is as follows: XXXXXXXXXX (OPCO I) and XXXXXXXXXX (OPCO II) are private corporations and Canadian-controlled private corporations, as defined under subsections 89(1) and 125(7) of the Act, respectively. ...

The New Preferred Shares will not be, at any time during the implementation of the proposed transaction:- the subject of any undertaking that is referred to in subsection 212(2.2) as a guarantee agreement,- the subject of a dividend rental arrangement as the term is defined in subsection 248(1),- issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)) or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 26. ...