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Results 23301 - 23310 of 29012 for consideration

1999 Ruling 9901923 F - PAPILLON

La société peut acquérir de gré à gré tout ou partie des actions de catégorie «A» émises et en circulation de tel détenteur, à tel moment, de telle manière et pour telle considération que le conseil d'administration détermine conjointement avec le ou les détenteurs des actions de catégorie «A».- Catégorie «C»: Votantes (XXXXXXXXXX votes par action), non participantes, et ne donnent droit à aucun dividende. ... La société peut acquérir de gré à gré tout ou partie des actions de catégorie «D» émises et en circulation de tel détenteur, à tel moment, de telle manière et pour telle considération que le conseil d'administration détermine conjointement avec le ou les détenteurs des actions de catégorie «D». ... Il devra alors être déduit de la JVM de cette contrepartie, la valeur de toute considération autre qu'en action de catégorie «D» qui a été émise ou payée par la société pour cette contrepartie. ...

4 April 1991 Internal T.I. 9027237 F - An Audit Perspective of Capital Markets

Considerations: a) trader or dealer recognizes all transactions on income account b) adventure in the nature of trade c) intention of taxpayer including secondary intention d) number and frequency of transactions e) length of holding time f) method of disposition g) nature of the transaction 2. ... Provided the assignment of the debt by the original lender to a new lender does not constitute a novation [FN*: Note: A novation occurs when an original obligation is discharged by agreement of the parties and a new obligation with new consideration is undertaken, usually, but not necessarily, on the same terms, with a different creditor or debtor. ... Instead, it is viewed as inherent in the determination of any gain or loss on the forward contract, which gain or loss can only be determined at the time of contract fulfillment and is equal to the difference between the payment made under the contract and the Canadian-dollar value of the consideration received therefore where such consideration is translated to Canadian dollars at the spot rate in effect on the date of delivery. ...

Mitchell v. Canada (Minister of National Revenue), docket T-434-90

In recognition of this difficulty, Lamer C.J. made it clear that courts must be flexible in their consideration of pre-contact activities. ...

2013 Ruling 2013-0491651R3 - Cross-Border Butterfly

On the incorporation of TC, Foreign SpinCo will subscribe for one or more common shares of TC for nominal consideration. 6. ... As consideration for the Distribution Property, TC will issue TC Preferred Shares to DC having an aggregate FMV at that time equal to the aggregate FMV of the Distribution Property transferred to TC. 94. TC will jointly elect with DC, in prescribed form and within the time limits referred to in subsection 85(6), to have the rules in subsection 85(1) apply to the transfer of each eligible property to TC and in respect of which the TC Preferred Shares have been issued as full consideration for the transfer of the Distribution Property as described in Paragraph 92. ...

2 March 2000 Income Tax Severed Letter 2000-0M20360 - PRESENTATION ON INDIAN TAXATION

After consideration of the connecting factors, the Court found that the performance of her duties, being primarily for the Indians on reserve, the actual historical circumstances involving the relocation off reserve and Ms. ... This determination required the review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ... Afin de tenir compte de l'approche adoptée par cette Cour, on a pris en considération les nombreux arguments avancés par des groupes et particuliers indiens ainsi que par d'autres parties intéressées. ...

1999 Ruling 9820613 - DISTRESS PREFERRED SHARES - XXXXXXXXXX

XXXXXXXXXX will subscribe for and XXXXXXXXXX will issue to XXXXXXXXXX a certain number of Class XXXXXXXXXX preferred shares for nominal consideration. The number of shares subscribed for and issued will be equal to XXXXXXXXXX less that number of Class XXXXXXXXXX preferred shares issued to the Partnership as partial consideration for the purchase of the assets of the Partnership, as described in paragraph 51, below. 47. ... XXXXXXXXXX will pay to XXXXXXXXXX an annual fee (the "XXXXXXXXXX Put Fee") in the amount of $XXXXXXXXXX, as consideration for entering into the XXXXXXXXXX Put Agreement. ...

29 June 2010 GST/HST Ruling 84050 - Gift Cards Supplied at No Charge

The Retailer, among other things, supplies gift cards, namely XXXXX, to its customers generally for consideration, although some are supplied for no consideration to certain customers for various reasons; for example, XXXXX. 3. ... Further, no consideration has been given for the voucher, so the criterion of a gift certificate of consideration being given is not met and, therefore, a gift card supplied for no consideration as described in the above facts is not a gift certificate within section 181.2. ... Subsequently, when the free gift card is used by the bearer as full or partial payment towards the consideration for a supply to the bearer, the payment or receipt of the value of the gift card towards that consideration is treated in the same manner as the payment of money as consideration for the supply. ...

21 October 2011 GST/HST Interpretation 135932r - GST/HST INTERPRETATION - [...] [Supplies of design, construction, financing and management services of a facility]

To the extent that any consideration become payable before January 1, 2008, the GST at 6% applies to that consideration. ... Subsection 168(2) provides that, notwithstanding subsection 168(1), where consideration for a taxable supply becomes due on more than one day, tax is payable on the day any part of the consideration becomes due and is based on the consideration that becomes due on that day. As the consideration for the construction of the [facility] was not paid by Hospital Authority at any time before consideration for the supply became due, it must be determined when consideration for the supply became due. ...

2004 Ruling 2004-0065921R3 - Conversion of corporations into LLCs

(b) "Share" means a membership interest in LLC 3; (c) "Stockholder" means each person signing the LLC 3 Agreement and any person who subsequently obtains a Share in LLC 3, in each case in its capacity as a Stockholder of LLC 3; (d) "Capital" of Shares is the aggregate of all amounts paid to LLC 3 and the monetary value at the time of contribution of property contributed to LLC 3 (in each case including amounts paid or contributed prior to USco 3's conversion to LLC 3) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 3 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 3 Agreement. ... (b) "Share" means a limited liability company interest in LLC 2; (c) "Stockholder" means each person signing the LLC 2 Agreement and any person who subsequently obtains Shares in LLC 2, in each case in its capacity as a Stockholder of LLC 2; (d) "Capital" of Shares is the aggregate of all amounts paid to LLC 2 and the monetary value at the time of contribution of property contributed to LLC 2 (in each case including amounts paid or contributed prior to USco 2's conversion to LLC 2) in consideration for the issuance of Shares together with any amounts added thereto by the Board of Managers or the Stockholders in accordance with the provisions of the LLC 2 Agreement, less the aggregate of all amounts by which such capital has been reduced by the Stockholders or the Board of Managers in accordance with the LLC 2 Agreement. ...

2013 Ruling 2012-0458091R3 - XXXXXXXXXX - loss consolidation

The Preferred Shares will be redeemable by the issuer at any time for a redemption price equal to the fair market value of the consideration for which the shares are issued, plus any accrued but unpaid dividends. ... At any time during the implementation of the proposed transactions described in this letter, the Preferred Shares will not be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a "guarantee agreement"; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). ...

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