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Results 8031 - 8040 of 29010 for consideration

1998 Ruling 9825983 - SUPP. TO 3-971606

Newco 3 will subscribe for a nominal number of common shares of each of Newco3Sub1, Newco3Sub2 and Newco3Sub3 for nominal consideration. ... C will subscribe for one common share in the capital of Newco 1, Newco 2 and Newco 4, as the case may be, for nominal consideration. ... Newco 1 will subscribe for a nominal number of common shares of each of Sub-Newco1A and Sub-Newco1B for nominal consideration. ...

Fiera Foods Company v. The King, 2023 TCC 140

The taxable supply was made in Ontario such that the consideration for the supply is subject to tax under subsections 165(1) and (2). The taxable supply is not described in Schedule VI of the ETA and therefore is not a zero-rated supply. [167] [238] Consequently, the Appellant was required to pay to the Crown tax at the rate of 13% of the consideration for the taxable supply made by each Agency to the Appellant on the earlier of the day the consideration for the supply was paid and the day the consideration for the supply became due. ... Subsection 152(1) deems when consideration for a taxable supply becomes due. [159] Subsection 123(1). ...

2012 Ruling 2011-0421261R3 - Partnership Allocation

The Class B Common Shares of BCo were issued for cash consideration to ACo (or a predecessor company) and the Vendors in XXXXXXXXXX, and are currently owned as follows: Shareholder Consideration in XXXXXXXXXX $ Number of Class B Common Shares Issued ACo XXXXXXXXXX XXXXXXXXXX Vendors XXXXXXXXXX XXXXXXXXXX Total XXXXXXXXXX XXXXXXXXXX 12. ... ACo has subscribed for and GP Co has issued XXXXXXXXXX common shares of GP Co to ACo for an aggregate consideration of $XXXXXXXXXX. ... BCo will receive additional Class A Units of New LP as consideration for the transfer of assets by BCo to New LP, as described in paragraph 21 below, and (b) ACo, which intends to subscribe for Class B Units of New LP for cash consideration from time to time as funds are required by New LP. ...

30 November 1996 Ruling 9719643 - INTEREST DEDUCTIBILITY - PUC REDUCTION

The XXXXXXXXXX Note has a principal amount equal to the agreed amount for the purposes of the subsection 85(1) election. 29.The XXXXXXXXXX common shares issued as the balance of the consideration for the XXXXXXXXXX shares had a fair market value equal to the fair market value of the XXXXXXXXXX shares less the principal amount of the XXXXXXXXXX Loan. ... Consideration for the shares of XXXXXXXXXX shares consisted of (i) an interest bearing note payable to XXXXXXXXXX ("XXXXXXXXXX Note 2") and (iii) common shares of XXXXXXXXXX. 42.With respect to the transfer of the XXXXXXXXXX shares, XXXXXXXXXX will file a joint election under subsection 85(1) within the time referred to in subsection 85(6). ... Our ruling is based on the Act in its present form and does not take into consideration any proposed amendments to the Act. ...

2 April 2001 External T.I. 2001-0068935 - SURROGOCY ARRANGEMENTS

Reasons: The payments are in consideration for services rendered according to our understanding of the contractual relationship between the "Intended Parents" (the payors) and the "Gestational Carrier" (the beneficiary). ... In the case submitted, however, the payments cannot be said to be gifts, that is, voluntary transfers of real or personal property without consideration, since they are required under the surrogacy contract. ... Moreover, the payments are not "without consideration" as the Intended Parents do receive valuable services in exchange, without which no payments would be made. ...

25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE

A company can issue its own shares as "consideration for the acquisition of property", as Lord Greene M.R. said. ... When the directors of a CBCA corporation determine the consideration for the issue of the shares as consideration for property, it is no different from directors of a corporation deciding to issue a certain number of par value shares as consideration for property. ... Rather than consideration being referable to the product of the par value of the share times the number of shares issued, the consideration is referable to the stated capital of the shares being issued as determined by the directors. ...

The Queen v. Rockmore Investments Ltd., 76 DTC 6156, [1976] CTC 291 (FCA)

Apart from these provisions, I know of no special considerations to be taken into account from a legal point of view in deciding whether an activity or situation constitutes the carrying on of a business for the purposes of Part I of the Income Tax Act. ...

Canada v. Phénix, 2001 DTC 5367 (FCA)

Her Majesty the Queen; and (d) many cases were awaiting this decision, both in the Tax Court of Canada and in the Appeals Division of the Canada Customs and Revenue Agency. [6] I doubt that I am able to take into consideration the facts referred to above in paragraphs (b) and (d). ...

The Queen v. Lagiorgia, 87 DTC 5378, [1987] 2 CTC 151 (FCA)

As indicated, however, my consideration of them does not lead me to the conclusions sought by counsel. ...

Wiebe v. The Queen, 87 DTC 5068, [1987] 1 CTC 145 (FCA)

In particular, they affected the consideration to be paid by adding the important requirement of a personal guarantee with the bank to the extent of $20,000; they also drastically affected the terms upon which each appellant became a shareholder by requiring the concurrent execution of a buy-back agreement. ...

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