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Technical Interpretation - Internal

9 February 1990 Internal T.I. 59439 F - Inadequate Consideration - Redemption of Shares

9 February 1990 Internal T.I. 59439 F- Inadequate Consideration- Redemption of Shares Unedited CRA Tags 69(1)(b), 84(3) 19(1) File No. 5-9439   S. ...
Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter - Consideration of Preferential Pricing on RRSP as Permitted Benefits

7 November 1990 Income Tax Severed Letter- Consideration of Preferential Pricing on RRSP as Permitted Benefits Unedited CRA Tags 146(2)(c.4) Dear Sirs: Re: Benefits permitted under section 146(2)(c.4) This is in reply to your letter of October 23, 1990, requesting our opinion whether preferential pricing on registered retirement saving plans ("RRSPs") for certain groups was allowed. ...
Public Transaction Summary

Rayonier AM/Tembec -- summary under Canadian Buyco

Each Tembec Share that is a Stock Electing Share shall be transferred to Rayonier Am in exchange for the Per Share Stock Consideration of 0.2302 of a share of Rayonier AM Common Stock (increased to 0.2542.) ... Share and cash election A registered holder of Tembec Shares may elect the Per Share Cash Amount; or (ii) Per Share Stock Consideration, subject to proration to ensure that no more than 63.3% (increased to 67%) of the aggregate Tembec Shares will receive the Per Share Cash Amount and no more than 36.7% (decreased to 33%) of the aggregate Tembec Shares will receive the Per Share Stock Consideration. ... U.S. tax consequences The exchange of Tembec Shares for the consideration pursuant to the Arrangement will be a taxable transaction for Code purposes. ...
Technical Interpretation - External

6 November 1990 External T.I. 9030155 F - Consideration of Preferential Pricing on RRSP as Permitted Benefits

6 November 1990 External T.I. 9030155 F- Consideration of Preferential Pricing on RRSP as Permitted Benefits Unedited CRA Tags 146(2)(c.4), 146(13.1), 6(1)(a) 24(1) 5-903015   M.P. ...
Miscellaneous severed letter

9 February 1990 Income Tax Severed Letter AC59439 - Inadequate Consideration for Redemption of Shares

9 February 1990 Income Tax Severed Letter AC59439- Inadequate Consideration for Redemption of Shares Unedited CRA Tags 69(1)(b), 84(3) 5- 9439 19(1) S. ...
Miscellaneous severed letter

8 March 1990 Income Tax Severed Letter AC59601 - Inadequate Considerations

8 March 1990 Income Tax Severed Letter AC59601- Inadequate Considerations Unedited CRA Tags 69(1), 20(1)(c) 19(1) 5-9601 D.S. ...
Miscellaneous severed letter

2 July 1992 Income Tax Severed Letter 9207725 - Inadequate Consideration

2 July 1992 Income Tax Severed Letter 9207725- Inadequate Consideration Unedited CRA Tags 69(11) 920772 A.Y. ...
Technical Interpretation - External

19 December 1991 External T.I. 9126915 F - Attribution of Gain to Transferor where Nil Consideration

19 December 1991 External T.I. 9126915 F- Attribution of Gain to Transferor where Nil Consideration Unedited CRA Tags 74.2(1), 74(2), 73(1) 912691 Dear:19(1) Re: Application of Subsection 74.2(1) of the Income Tax Act (the Act} We are writing in reply to your letter of August 19, 1991, wherein you requested that we confirm your views on the interpretation of subsection 74.2(1) of the Act as it relates to the following situation. ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property

7 October 1990 Income Tax Severed Letter- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21)(d.1) Dear Sirs: Re: XXX "Timber Quota Certificate"/"Timber Licence") Paragraph 13(21)(d.1) of the Income Tax Act (the "Act") We are writing in reply to your letter of September 11, 1990, in which you request our interpretation of whether a "Timber Quota Certificate" and a "Timber License" constitute a timber resource property as defined in paragraph 13(21)(d.1) of the Act. ...
Technical Interpretation - Internal

21 June 1994 Internal T.I. 9408087 - TIMING CONSIDERATION TO A HOME RELOCATION LOAN

21 June 1994 Internal T.I. 9408087- TIMING CONSIDERATION TO A HOME RELOCATION LOAN Unedited CRA Tags 110(1)(j) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

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