Search - consideration
Results 2851 - 2860 of 29012 for consideration
Ruling summary
2018 Ruling 2017-0683941R3 - Split-up transactions -- summary under Subparagraph 55(3)(a)(ii)
Daughter will transfer all of her Amalco shares to Newco in consideration for redeemable retractable non-voting non-cumulative Newco Class A Special Shares, with a joint s. 85(1) election being made. ...
Technical Interpretation - External summary
28 May 2021 External T.I. 2021-0889611E5 - ACB and Safe income allocation on corporate reorg. -- summary under Paragraph 55(2.1)(c)
The Holdco 2 preferred shares held by Holdco 1 are redeemed in consideration for Holdco 2 assigning Newco A Promissory Note. ...
Technical Interpretation - External summary
5 August 2022 External T.I. 2021-0877051E5 F - TOSI and excluded amount -- summary under Related Business
In 2019, Opco (which did not carry on a services business) purchased for cancellation its shares held by Investco in consideration for an interest-bearing term note (the "Note"), after which, C-3 Trust held 80 out of the 100 non-voting common shares of Opco, as well as 80 voting preferred shares of Opco. ...
Ruling summary
2023 Ruling 2022-0941241R3 - Internal reorganization: subs and partnerships -- summary under Subsection 88(1)
2023 Ruling 2022-0941241R3- Internal reorganization: subs and partnerships-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) sequential wind-ups of child, then grandchild, respected notwithstanding that their dissolutions held in abeyance until resolution of litigation with CRA Background and preliminary transactions After preliminary transactions (including the sale by Partnerships C and D of Canadian resource properties (CRP) to ParentCo for cash consideration so as to reduce the balances in their successor CCEE (deductible in accordance with s. 66.7(3)) and CCOGPE (deductible in accordance with s. 66.7(5)) to minimize the risk that s. 66.7(16) would apply as a consequence of CRP transfers to ParentCo on the winding-up of those Partnerships): ParentCo and its historic subsidiary SubCo will be the only partners of the general partnership, Partnership C; The partners of another general partnership, Partnership D will be Partnership C, ParentCo and SubCo's newly-incorporated subsidiary, NewCo2. ...
Ruling summary
2023 Ruling 2022-0943871R3 - Cross-border spin-off butterfly -- summary under Subclause 55(3.1)(b)(i)(A)(II)
DC will transfer all its assets relating to Spin Business (being the shares of Sub 1) to TC in consideration for the assumption of certain liabilities of DC and the issuance of TC preferred shares. ...
Old website (cra-arc.gc.ca)
Nova Scotia HST Rate Increase: Sales and Rentals of Non residential Real Property
When consideration becomes due For GST/HST purposes, in the case of a written agreement for a supply of real property made by way of lease, consideration becomes due on the day the lessee is required to pay the consideration under the agreement. ... When consideration is paid without becoming due For GST/HST purposes, in the case of a supply of real property made by way of lease, consideration is paid without having become due when the lessee pays the consideration before the lessee is required to pay the consideration (e.g., payment is made before the consideration becomes due under a written agreement for the supply). ... The individual pays consideration for the accommodation in full on May 15, 2010. ...
Scraped CRA Website
Nova Scotia HST Rate Increase: Sales and Rentals of Non-residential Real Property
When consideration becomes due For GST/HST purposes, in the case of a written agreement for a supply of real property made by way of lease, consideration becomes due on the day the lessee is required to pay the consideration under the agreement. ... When consideration is paid without becoming due For GST/HST purposes, in the case of a supply of real property made by way of lease, consideration is paid without having become due when the lessee pays the consideration before the lessee is required to pay the consideration (e.g., payment is made before the consideration becomes due under a written agreement for the supply). ... The individual pays consideration for the accommodation in full on May 15, 2010. ...
Current CRA website
Nova Scotia HST Rate Increase: Sales and Rentals of Non-residential Real Property
When consideration becomes due For GST/HST purposes, in the case of a written agreement for a supply of real property made by way of lease, consideration becomes due on the day the lessee is required to pay the consideration under the agreement. ... When consideration is paid without becoming due For GST/HST purposes, in the case of a supply of real property made by way of lease, consideration is paid without having become due when the lessee pays the consideration before the lessee is required to pay the consideration (e.g., payment is made before the consideration becomes due under a written agreement for the supply). ... The individual pays consideration for the accommodation in full on May 15, 2010. ...
Ruling summary
2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Distribution
DC transferred a proportionate share of each type of its property to "Newco," a newly-incorporated subsidiary (with such transferred assets relating to the Canadian Transferred Services Business and including the shares of some of its subsidiaries and portions of the vendor take-back notes ("Notes 1 and 2") received on a previous sale of subsidiaries in consideration for additional Newco common shares and the assumption of liabilities related to the Canadian Transferred Services Business. ...
Old website (cra-arc.gc.ca)
Harmonized Sales Tax: Leases of Real Property in Ontario and British Columbia
When consideration becomes due For GST/HST purposes, in the case of a written agreement for a supply of real property made by way of lease, consideration becomes due on the day the lessee is required to pay the consideration under the agreement. ... When consideration is paid without becoming due For GST/HST purposes, in the case of a supply of real property made by way of lease, consideration is paid without having become due when the lessee pays the consideration before the lessee is required to pay the consideration (e.g. payment is made before the consideration becomes due under a written agreement for the supply). ... The individual pays consideration for the accommodation in full on May 15, 2010. ...