Search - consideration
Results 23561 - 23570 of 29042 for consideration
Ruling
2002 Ruling 2002-0123813 - Loss Consolidation within Affiliated Grp.
The dividend rate will be determined at the time of the Proposed Transactions, and subsequently, at the beginning of each taxation year; (c) redeemable at any time at the option of the holder or Newco for cash or by delivering a financial asset of Newco (including the Aco Demand Loan issued under Paragraph 12) for an amount equal to the aggregate of the fair market value of the consideration for which the shares were issued and any unpaid dividends. ...
Technical Interpretation - Internal
1 May 2002 Internal T.I. 2001-0114347 - EXCLUDED PRODUCTION-25 YEAR PERIOD
We do not have sufficient information to comment further on this point, but just raise the question for your consideration. ...
Technical Interpretation - Internal
30 April 2002 Internal T.I. 2002-0130827 - Insurance commissions paid to non-resident
The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work [...], any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience [...] ...
Ruling
2001 Ruling 2001-0108843 - Carrying on Business in Canada
Holdco's subsidiaries would pay management fees to CanSub in consideration of the Executive and G&A Services. 38. ...
Ruling
2002 Ruling 2002-0136313 - Safe Income Extraction
However, Canco will not be indemnified against commercial risks and will be subject to market considerations subsequent to its acquisition of Newco shares and the proposed resale of the Pubco shares. ...
Ruling
2002 Ruling 2001-0116133 - XXXXXXXXXX Storage-Carrying on Business in Canada
XXXXXXXXXX Subco provides these services in consideration for a service fee. 4. ...
Ruling
2002 Ruling 2002-0132453 - Storage of XXXXXXXXXX - Carrying on business
As consideration for providing services to Parentco under the Subco Services Agreement, Subco is paid a monthly fee of US$XXXXXXXXXX (the "Service Fee"). ...
Ruling
2002 Ruling 2002-0141763 - GIFT SUBJECT TO CONDITIONS
To the extent the whole of the annual net income is not fully expended in a year, such excess will be added to the trust funds. 19) If at any time after the start of construction of the Project but prior to the Project being substantially complete there remain undrawn trust funds and the Public Foundation has been declared bankrupt or insolvent or has entered into liquidation, then during such period no funds may be withdrawn from the Fund for any purpose whatsoever without the prior written consent of the Donors, and if such default is not cured within a certain period, then the Donors will in writing designate one or more registered charities qualified to issue receipts under the Act to which the Public Foundation may make contribution and the Public Foundation will pay to such designee specified by the Donors forthwith, after such written designation has been made by the Donors, all of such remaining undrawn trust funds. 20) Charity A will be responsible for designing, obtaining and approving architectural plans, all required building permits, including without limitation municipal, provincial and federal permits and all approvals and consents from any person or persons whose approvals or consents are required. 21) No mortgage will encumber the properties prior to the XXXXXXXXXX anniversary of the start of construction of the Project, without the prior written consent of the Donors, except for mortgages or charges given as collateral or additional security to secure construction funds advanced by a Canadian chartered bank, trust company, credit union or other recognized and governmentally regulated financial institution carrying on business in XXXXXXXXXX for a construction loan XXXXXXXXXX% of the face value and proceeds of such loan are used directly for the construction of the Project. 22) During each year of construction of the Project, the Public Foundation and Charity A will cause to be prepared annually, in respect of the Project, financial reports and will deliver the same to the Donors. 23) For a period of XXXXXXXXXX years, the Donors will be kept informed on a regular basis by Charity A of the results of any consideration or intention, on the part of Charity A, to carry out any reorganization, restructuring, merger or amalgamation. 24) Following completion of the construction of the Project, Charity A alone will be responsible for the operation and maintenance of the completed Project and at all times thereafter will operate and maintain the Project. ...
Technical Interpretation - External
4 November 2002 External T.I. 2002-0158885 F - Alloc. of Safe Inc. & Disc. Div. Shares
For example, such allocation would require, among other things, the consideration of all of the terms and conditions attached to the various classes of shares, an analysis of the terms of a unanimous shareholder agreement, if any, and an analysis of the applicable corporate law. ...
Technical Interpretation - Internal
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1)
It is reasonable to conclude that one spouse desired to confer a benefit on the other spouse by receiving consideration which is less than the fair market value of the property transferred. 2. ...