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Ruling

1999 Ruling 9918303 - TAXABLE CANADIAN PROPERTY

As consideration for the XXXXXXXXXX Bonds and Units, the Bond Trustee transferred to the Corporation the security and foreclosure rights it held in connection with the Bonds. ...
Ruling

1999 Ruling 9921413 - CANADIAN FILM OR VIDEO PRODUCTION TAX CREDIT

Prior to Aco's XXXXXXXXXX year-end, Aco will acquire all of Bco's shares in Old Prodco for consideration representing the current fair market value of Old Prodco. ...
Ruling

1999 Ruling 9931653 - BUTTERFLY REORGANIZATION

No other consideration will be paid by Newco for such shares. The addition to the stated capital of the Newco common shares in respect of each such transfer will be equal to the FMV of the Class A preferred shares of Propertyco that were transferred. ...
Technical Interpretation - External

20 March 2000 External T.I. 2000-0002565 - CANADA COUNCIL AWARDS

For instance, you indicate that the merit of the musician's proposed project is one of the considerations for receiving the award; however, it is unclear how much weight is allocated to this factor and which other factors are considered. ...
Ruling

1999 Ruling 9927473 - TERM PREFERRED SHARES

ACO and BCO will jointly elect in prescribed form and in accordance with subsection 85(6) of the Act to have the provisions of subsection 85(1) of the Act apply to the assignment of BCO Debt in consideration for the issuance of the Preferred Shares. 21. ...
Ruling

2000 Ruling 9929203 - FOREIGN TAX CREDIT - FOREIGN ELECTION

Acquireco will purchase pursuant to a Plan of Arrangement all the issued and outstanding common and preferred shares of Canco for consideration comprised of the remaining cash and all of the Buyerco common shares it acquired in step 8 above. ...
Technical Interpretation - External

10 April 2000 External T.I. 2000-0004715 - DEFERRED INCOME OF FARMERS-AUCTION SALE

While certain auctioneers may as a practical consideration defer payment to the vendor until such time as the purchaser's cheque has cleared, this does not change the position that the funds belong to the vendor as of the time the auctioneer has declared the livestock to be sold. ...
Ruling

1999 Ruling 9926143 - LIMITED PARTNERSHIP

Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...
Ruling

2000 Ruling 2000-0038873 - Affiliated Group Loss Utilization

On XXXXXXXXXX, the shares of XXXXXXXXXX/Lossco were transferred by XXXXXXXXXX/Parentco to XXXXXXXXXX/Subco for cash consideration. 9. ...
Ruling

2000 Ruling 2000-0038963 - Affiliated group of persons loss ATIL

In consideration for the transfer of the Depreciable Assets XXXXXXXXXX will issue to XXXXXXXXXX common shares. 8. ...

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