Search - consideration
Results 22961 - 22970 of 29013 for consideration
Ruling
2001 Ruling 2001-0069703 - LOSS CONSOLIDATION
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. ...
Ruling
2001 Ruling 2000-0057243 - OPTION EXCHANGE, PARENT MERGER
A Special Corporate resolution provides for the issuance of shares and immediate conversion into shares of the merged corporation at the merger exchange rate. 2) Since the bonus plan is a separate and distinct plan, we can accept that the bonus is not consideration for the exchange of the options. ...
Technical Interpretation - External
12 October 2001 External T.I. 2001-0078715 - QUALIFIED FARM PROPERTY
In our opinion, the position in the original interpretation is supported in law when due consideration is given to the nature of a co-owner's rights in a particular piece of land. ...
Technical Interpretation - Internal
16 August 2001 Internal T.I. 2001-0079317 F - RESIDENCE PRINCIPALE DEMI-HECTARE
Nous vous fournissons des éléments de droit qui peuvent être pris en considération dans l'analyse de votre dossier. ...
Technical Interpretation - Internal
22 June 2001 Internal T.I. 2001-0065467 - AMORTIZATION OF BROADCAST LICENSES
The licensor can "pull-back" shows from the taxpayer after one or two showings without paying much or any consideration. 9. ...
Technical Interpretation - Internal
28 November 2001 Internal T.I. 2001-0091247 - Employer Stock Opt. & Section 116116(5)
With respect to the cost to Parentco of Canco XXXXXXXXXX Shares as a result of the exercise of the right of first refusal by Parentco, we are of the opinion that such cost would be equal to the stated capital or paid-up capital of the common shares of Parentco issued to XXXXXXXXXX in consideration for the transferring of the Canco XXXXXXXXXX Shares to Parentco by XXXXXXXXXX. ...
Technical Interpretation - External
11 December 2001 External T.I. 2001-0111495 - MATCHABLE EXPENDITURES
FACTS Our understanding of the relevant facts is as follows: Subsection (2) of the Notice of Ways and Means tabled in the House of Commons on September 18, 2001 states: "(2) Subsection (1) applies in respect of expenditures made by a taxpayer on or after September 18, 2001 in respect of a right to receive production, (in this subsection referred to as the "right"), except if (a) the expenditure is (i) required to be made under a written agreement made by the taxpayer before September 18, 2001, (ii) made under, or described in, the terms of a prospectus, preliminary prospectus or registration statement that is, before September 18, 2001, filed with a public authority in Canada in accordance with the securities legislation of Canada or of a province and, if required by law, accepted for filing by the public authority before September 18, 2001, or (iii) made under, or described in, the terms of an offering memorandum distributed as part of an offering of securities if (A) the memorandum contains a complete, or substantially complete, description of the securities contemplated in the offering as well as the terms and conditions of the offering, (B) the memorandum was distributed before September 18, 2001, (C) solicitations in respect of a sale of the securities contemplated in the offering have been made before September 18, 2001, and (D) the sale of the securites contemplated in the offering is substantially in accordance with the memorandum; (b) the expenditure is made before 2002; (c) the expenditure is paid in consideration for services that are rendered in Canada before 2002 in respect of an activity, or a business, all or substantially all of which is carried on in Canada; (d) there is no agreement, or other arrangement, under which the obligation of any taxpayer in respect of the expenditure can be changed, reduced or waived if there is a change to, or an adverse assessment under, the Act; (e) if the right is, or is related to, a tax shelter investment, a tax shelter identification number in respect of the tax shelter was obtained before September 18, 2001; and (f) if the expenditure is made under, or described in, the terms of a document that is a prospectus, a preliminary prospectus, a registration statement or an offering memorandum (and regardless of whether the expenditure is also made under a written agreement) (i) all of the funds raised pursuant to the document that may reasonably be used to make a matchable expenditure are raised before 2002, (ii) all or substantially all of the securities distributed pursuant to the document for the purpose of raising the funds described in subparagraph (i) are acquired before 2002 by a person who is not (A) a promoter, or an agent of a promoter, of the securities, (B) a vendor of the right, (C) a broker or dealer in securities, or (D) a person who does not deal at arm's length with a person referred to in clause (A) or (B), and (iii) all or substantially all of the funds raised pursuant to the document before 2002 are used to make expenditures that are required to be made pursuant to agreements in writing made before September 18, 2001. ...
Technical Interpretation - External
19 December 2001 External T.I. 2001-0077175 F - FRAIS ENCOURUS POUR UNE INVENTION
Les facteurs pertinents qui doivent être pris en considération diffèrent selon la nature et la portée de l'activité ou du travail. ...
Ruling
2001 Ruling 2001-0087073 - RETIREMENT COMPENSATION ARRANGEMENT
As consideration for the assumption by Parent of the obligation to provide post-retirement benefits, Subsidiary will establish the RCA Trust. ...
Miscellaneous severed letter
2001 Income Tax Severed Letter 2001-0107241 - Supplemental ruling
On or about XXXXXXXXXX, DC2 disposed of some of its Pubco2 shares at fair market value for cash consideration only and realized a capital gain. ...