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An existing micro-cap TSXV-listed company will raise cash by selling its only asset and closing a private placement, and will also issue shares to the new Trust in exchange both for units of the Trust and for cash, and then will redeem out all its common shareholders (other than the Trust) in consideration for cash or the transfer to them of the Trust units. ...
2 July 2012- 3:24pm CRA corrects error in GST/HST Policy Statement re discounted gift certificates Email this Content In the version of Policy P-202 which was outstanding up until April of this year, CRA stated that one of the characteristics of a gift certificate (which is treated for GST and HST purposes similarly to money) is that the consideration for its purchase "is given in the amount of the stated value. ...
The Alpha shares will then be transferred to Fission under the Alpha Plan of Arrangement in consideration for Fission shares and nominal cash, resulting in Fission being owned approximately 49.3% and 47.9% by the former Alpha and Fission shareholders, and 2.8% by some new Alpha (flow-through share) investors. ...
Email this Content When asked whether a sale of property in Quebec for consideration of one dollar could qualify as a gift for purposes of s. 69(1)(c), CRA stated that in the absence of sham, this was a function of the legal effect under Quebec law of the governing contract of acquisition. ...
Miller J was not informed of the 2 nd order supply rule in s. 185(1), she also considered that even if the expenses had been incurred by the LP in order to issue LP units in consideration for receiving the IPO funds, that represented an exempt supply which would not have entitled the LP to ITCs. ...
22 January 2014- 11:25am The income tax and HST treatments of Bitcoin barters are at odds Email this Content CRA considers that in a transaction where a merchant (or other business) sells goods or services for Bitcoins, the profit for income tax purposes is based on the normal selling price of the property or services, whereas the consideration for HST/GST purposes is the value of the Bitcoins. ...
As a result, sufficient stacking of corporations can result in an inability of all group members to make the ETA s. 156 nil consideration election. ...
As the consideration paid by Antoni was inflated, s. 160 applied to make LCR liable for Antoni’s unpaid taxes (jointly with LCR’s shareholder given subsequent dividends to him). ...
More recently, CRA has substantially qualified this view by confirming that it would consider that “where a person provides property or a service to a person for no consideration but receives interest or dividend revenue from that person it is unlikely that ITCs would be available.” ...
6 March 2016- 11:29pm Lowe’s acquisition of RONA through a Nova Scotia ULC is not conditional on approval of prefs Email this Content It is proposed that RONA will be acquired for cash consideration under a Quebec Plan of Arrangement. ...