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Therefore, I have forwarded your letter to the Honourable Paul Martin, Minister of Finance, for his consideration of your suggestion that the regulation be harmonized with the Ontario Teachers Pension Act. ...

On the amalgamation, NR Corp received 10% of the issued common shares of Publico as consideration for its shares of the capital stock of one of the predecessor corporation. ...

OUR VIEWS As stated in paragraph 3 of Interpretation Bulletin IT-110R2, we consider that a gift, for purposes of subsections 110.1(1) and 118.1(1) of the Act, is a voluntary transfer of property without valuable consideration. ...

David Dodge, Deputy Minister of Finance for his consideration. I wish to thank you for bringing this matter to my attention. ...

The $18,000 off-set plus the $2,000 Deferred Cash Purchase Ticket was the consideration for the $20,000 wheat delivered. ...

DEPARTMENT'S POSITION Whether all, or any portion of, such fees or payments are subject to withholding tax is a question of fact which can only be determined with full knowledge of all of the facts concerning a particular situation and after consideration is given to the provisions under paragraph 212(1)(d) of the Act, Regulation 105 and the Canada-U.S. ...

In such case, fair market value consideration should be received by the Canadian corporation in respect of any property (e.g. eligible capital property) that is transferred to the subsidiary. 3) The comments in IT-454 entitled "Business Transactions Prior to Incorporation" may be of assistance in reference to the treatment of business transactions carried out prior to incorporation of the corporation that is intended to carry on the business. ...

XXXXXXXXXX Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

Dunn Attention: XXXXXXXXXX June 10, 1996 Dear Sirs: Re: Taxable Preferred Shares We are writing in response to your correspondence of April 26, 1996 wherein you had requested that we give further consideration to our response of April 17, 1996 to you regarding the definition of "taxable preferred share" in subsection 248(1) of the Income Tax Act (the "Act") and, more specifically, whether that definition would apply to a share of a corporation the dividends upon which are attributable to the profits of a specific business division of a corporation. ...

As amendments to the Act relate to tax policy, which is the responsibility of my colleague, the Honourable Paul Martin, Minister of Finance, I have forwarded a copy of your letter to him for his consideration. ...