Search - consideration
Results 23481 - 23490 of 29042 for consideration
Ruling
2005 Ruling 2005-0155451R3 - Loss utilization among affiliated companies
In consideration for the transfer of the Transferred Assets, Parentco will issue a non-interest-bearing, demand promissory note with a principal amount equal to the fair market value of the Transferred Assets to Subco. ...
Technical Interpretation - External
1 February 2006 External T.I. 2005-0142411E5 F - Don entre vifs - bien agricole admissible
Lorsque la superficie totale du fonds de terre excède un demi-hectare, les restrictions quant à la superficie minimale d'un lot ou quant au morcellement ou à la subdivision du fonds de terre édictées par une loi ou un règlement d'une municipalité ou d'une province peuvent être prises en considération aux fins de la détermination de l'usage de l'excédent. ...
Technical Interpretation - Internal
29 May 2017 Internal T.I. 2017-0689161I7 - Paragraph 18(9.1)(a) - paying debt with new debt
LEGISLATION Subsection 18(9.1) Penalties, bonuses and rate-reduction payments — Subject to subsection 142.4(10), where at any time a payment, other than a payment that (a) can reasonably be considered to have been made in respect of the extension of the term of a debt obligation or in respect of the substitution or conversion of a debt obligation to another debt obligation or share, or (b) is contingent or dependent on the use of or production from property or is computed by reference to revenue, profit, cash flow, commodity price or any other similar criterion or by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation, is made to a person or partnership by a taxpayer in the course of carrying on a business or earning income from property in respect of borrowed money or on an amount payable for property acquired by the taxpayer (in this subsection referred to as a "debt obligation") (c) as consideration for a reduction in the rate of interest payable by the taxpayer on the debt obligation, or (d) as a penalty or bonus payable by the taxpayer because of the repayment by the taxpayer of all or part of the principal amount of the debt obligation before its maturity, the payment shall, to the extent that it can reasonably be considered to relate to, and does not exceed the value at that time of, an amount that, but for the reduction described in paragraph (c) or the repayment described in paragraph (d), would have been paid or payable by the taxpayer as interest on the debt obligation for a taxation year of the taxpayer ending after that time, be deemed, (e) for the purposes of this Act, to have been paid by the taxpayer and received by the person or partnership at that time as interest on the debt obligation, and (f) for the purpose of computing the taxpayer's income in respect of the business or property for the year, to have been paid or payable by the taxpayer in that year as interest pursuant to a legal obligation to pay interest, (i) in the case of a reduction described in paragraph (c), on the debt obligation, and (ii) in the case of a repayment described in paragraph (d), (A) where the repayment was in respect of all or part of the principal amount of the debt obligation that was borrowed money, except to the extent that the borrowed money was used by the taxpayer to acquire property, on borrowed money used in the year for the purpose for which the borrowed money that was repaid was used, and (B) where the repayment was in respect of all or part of the principal amount of the debt obligation that was either borrowed money used to acquire property or an amount payable for property acquired by the taxpayer, on the debt obligation to the extent that the property or property substituted therefor is used by the taxpayer in the year for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business. ...
Ruling
2017 Ruling 2016-0625301R3 - Merger of two related segregated fund trusts
Trust 1 will not receive any consideration for the transfer of property to Trust 2 in 11(b) above. 13. ...
Ruling
2018 Ruling 2017-0720901R3 - Use of a Surety Bond by RCA
Reasons: Substantially the same considerations apply as for an RCA securing its obligations with a letter of credit. ...
Technical Interpretation - External
18 December 1998 External T.I. E9829185 - CHILD SUPPORT
This deeming provision enables the payer to obtain a deduction under paragraph 60(b) of the Act, provided the payments otherwise qualify, and ensures that third party payments are taken into consideration in determining the amount the payer may deduct under paragraph 60(b) of the Act. ...
Ruling
30 November 1995 Ruling 9625233 - XXXXXXXXXX LIMITED PARTNERSHIP
XXXXXXXXXX will not be wound-up or amalgamate before it realizes of all of its fees related to the XXXXXXXXXX services. 16.In consideration of the XXXXXXXXXX services by XXXXXXXXXX will agree to pay to XXXXXXXXXX fees determined by reference to the XXXXXXXXXX Such fees will be calculated and paid as follows: (a)on or before the XXXXXXXXXX (b)the XXXXXXXXXX Fee calculated as described above under DEFINITIONS; and (c)an additional amount, being the XXXXXXXXXX Fees. ...
Technical Interpretation - Internal
3 March 1997 Internal T.I. 9700487 - CAPITAL OF A CREDIT UNION
However, consideration would have to be given to determine whether such contributions would be included in the particular financial institution's calculation of capital as contributed surplus or any other surplus. ...
Ruling
30 November 1995 Ruling 9616813 F - DÉMANTELEMENT STRUCTURE UTILISATION PERTES
Depuis la fin de l'exercice financier terminé le XXXXXXXXXX actions privilégiées Série XXXXXXXXXX ont été rachetées pour une considération de XXXXXXXXXX $ payée comptant. ...
Ruling
30 November 1996 Ruling 9629483 F - PARTICIPATION - SOCIÉTÉ DE PERS. AGRICOLE FAMILIALE
Les actions alors émises et en circulation de GESTION lors de son incorporation seront XXXXXXXXXX actions de catégorie «XXXXXXXXXX» (XXXXXXXXXX actions pour XXXXXXXXXX et XXXXXXXXXX actions pour XXXXXXXXXX) et XXXXXXXXXX actions de catégorie «XXXXXXXXXX» uniquement à XXXXXXXXXX, moyennant une considération de XXXXXXXXXX par action. ...