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Ruling

2004 Ruling 2003-0035821R3 - Taxation of Indian Trust

(F) The trust will qualify as a personal trust since the First Nation will be the settlor of the trust and the interest will not be acquired for consideration.. ...
Ruling

2004 Ruling 2004-0069011R3 - Incorporating a Partnership

Immediately before this winding-up, the Partnership will have no property other than the property received from Newco as consideration for the disposition to it of the Partnership's assets. ...
Technical Interpretation - Internal

30 September 2004 Internal T.I. 2004-0085051I7 F - Intérêts et indemnité additionnelle

La Reine, 2002 DTC 2065 (CCI) (ci-après " Ahmad "), le juge Miller qui avait à décider si les intérêts avant jugement reçus par un contribuable relativement à des dommages-intérêts étaient imposables, a statué comme suit sur le sens à donner au mot " intérêt ": " The starting point for the determination of the nature of an interest payment is the oft-cited definition of the Supreme Court of Canada in Re The Validity of Section 6 of the Farm Security Act, 1944 of the Province of Sasketchewan: Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another... ...
Technical Interpretation - Internal

28 April 2004 Internal T.I. 2004-0066991I7 F - Paiement incitatif

La Cour refusa la dépense pour les motifs suivants: " My reason for concluding that the premium in question is not an expenditure to earn the income of the " business " is that it is paid as consideration for an insurance policy pursuant to which the respondent is entitled to receive certain fixed weekly amounts for each week that he is "totally disabled and is thereby prevented from working for remuneration or profit" by reason of "disability due to accidental bodily injury", or by reason of "disability due to sickness", and to have such insurance coverage he must be a member of an organization that bargains on behalf of television and radio artists. ...
Ruling

2004 Ruling 2004-0094741R3 - Withholding Exemption -Minimum EBITDA

On XXXXXXXXXX, Holdco and Sellerco entered into a share purchase agreement pursuant to which Sellerco agreed to sell the Target Shares to Holdco (or its permitted assignee) in consideration for the Purchase Price. ...
Ruling

2004 Ruling 2004-0089721R3 - Exploration/new mine- CEE?

Consideration was given to using the existing mine shaft on the abandoned Y Co. mine site as a means to access Zone A. ...
Ruling

2000 Ruling 2000-0037133 - EMPLOYEE SAVINGS PLAN AND FUND

(m) Following the completion of the payments described in 26(l) above, the Swap Agreement will terminate and the Fund will be wound-up and/or merged with another FCPE ("Successor Fund"); a Participant holding Units at that time may elect to: (i) redeem Units in consideration for an amount per Unit equal to the Unit's Net Asset Value Per Unit; or (ii) receive units in the Successor Fund. ...
Technical Interpretation - External

5 June 2001 External T.I. 2000-0055765 F - Revenu gagné en main

La valeur de rachat correspondra à la JVM de la considération reçue lors de l'émission des actions, moins le montant de toute réduction du capital déclaré sur les actions. ...
Ruling

2000 Ruling 2000-0038133 - GROUP SAVINGS PLAN

A Participant holding Units at that time may elect to: (i) redeem Units in consideration for an amount per Unit equal to the Unit's Net Asset Value Per Unit; or (ii) receive units in the Successor Fund. ...
Ruling

2001 Ruling 2001-0089533 - Wind-up of NRO into Limited Partnership

The common shares were issued in consideration for, among other things, the acquisition of Canco Debt A and Canco Debt B and the payment of a stock dividend in XXXXXXXXXX. ...

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