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Reasons: Taxability/deductibility was a consideration in deciding the amount of the Payments by the parties and the courts, prior to the "new rules". ...

As you have already relayed these concerns to the Honourable Paul Martin, Minister of Finance, in a letter of April 14, 1998, I am certain your views will receive every consideration. ...

Subject to subsection 51(4) of the Act, section 51 will apply to any situation where a share of the capital stock of a corporation is acquired by a taxpayer in exchange for a capital property that is another share of the particular corporation and no other consideration is received for the old shares. ...

In any revised draft of this paper, consideration will be given to the comments and suggestions received from interested industry participants, and from consultations with officials at both CAVCO and the Department of Finance. ...

In this case, the cost of the property received by the annuitant from the RRSP will be the FMV of such property (which also equals the FMV of the property given up as consideration for such property). ...

Where paragraph 66(12.1)(a) applies, a taxpayer’s “cumulative Canadian exploration expenses” is reduced by consideration received (including revenue from a bulk sample where the original cost relates to CEE of the taxpayer). ...

Accordingly, in general terms, a gift is a voluntary transfer of property without valuable consideration. ...

In this regard, I have forwarded a copy of our correspondence to the Honourable Paul Martin, Minister of Finance, for his consideration. ...

As you note, the term “gross revenue” of a taxpayer for a taxation year is defined in subsection 248(1) of the Income Tax Act (the “Act”) as the total of two amounts and, assuming that only the first amount in that definition would be relevant to the situation under consideration, the “gross revenue” of the taxpayer would be comprised of “all amounts received in the year or receivable in the year (depending on the method regularly followed by the taxpayer in computing the taxpayer’s income) otherwise than as or on account of capital”. ...

Therefore, I am sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...