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Technical Interpretation - External

3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand

For example, if the adjusted cost base is equal to the fair market value of the preferred shares immediately before the payment of the dividend, there would be no safe income on hand that can be reasonably considered to contribute to the hypothetical capital gain with respect to the preferred shares. ...
Technical Interpretation - External

12 January 2011 External T.I. 2010-0388821E5 F - Discretionary dividend

The comments in this paper on stock options, stock dividends, and stock splits should also be considered. ...
Technical Interpretation - External

17 March 2005 External T.I. 2005-0118601E5 F - Sale of Shares-Transfer of Family Business

These elements should be considered in examining the purpose of section 84.1. ...
Technical Interpretation - External

23 October 1989 External T.I. 74195 F - Reporting Requirements Respecting Stripped Bonds

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue.  ...
Technical Interpretation - External

21 December 2023 External T.I. 2020-0866651E5 F - Transfer of life insurance

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...
Technical Interpretation - External

15 January 2025 External T.I. 2023-0983151E5 - METC - Assisted Human Reproduction expenses

Pursuant to paragraph 118.2(2)(a) of Act, an amount paid to a medical practitioner, dentist or nurse, or a public or licensed private hospital is considered to qualify as a medical expense of an individual only if it is paid in respect of a medical or dental service. ...
Technical Interpretation - External

20 April 2005 External T.I. 2005-0113961E5 F - Avocats nommés à la magistrature

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress (WIP) and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...
Technical Interpretation - External

23 November 2000 External T.I. 2000-0025955 F - AVOCATS NOMMES A LA MAGISTRATURE

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...

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