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Since the loan will be made to acquire a dwelling, consideration will have to be made as to whether the exemption in subsection 15(2.4) will apply. ...

Apart from the issue of reasonableness, as it would seem that this type of arrangement is not in accord with the purpose and spirit of the provisions in the Act related to exempt insurance policies we have referred this matter to the Department of Finance for their consideration. ...

Mco will dispose of its remaining common shares of Nco to Oco and Oco will issue common shares to Mco as consideration for the common shares of Nco. ...

Second consideration of our opinion 982557 (December 23, 1999, J. Stalker). ...

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). ...

In general, a RIF is an arrangement between a carrier and an annuitant under which, in consideration for property, the carrier undertakes to pay the yearly minimum amount to the annuitant and, where the annuitant so elects, to the annuitant's spouse or common-law partner after the annuitant's death. ...

Subsection 148(8) of the Act provides that where an interest of a policyholder in a life insurance policy is transferred to a child of the policyholder for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of disposition equal to the adjusted cost basis to the policyholder of the interest immediately before the transfer and to have been acquired by the child at a cost equal to that amount. ...

This interpretation would generally prevail across most if not all of Canada's income tax conventions that have been crafted by reference to the Model if the definition of "person" in the particular convention under consideration makes reference to both an "individual" and a "trust". ...

During our telephone conversation of October 23, 2001 (XXXXXXXXXX/Kohnen), we advised that if we were provided with complete disclosure concerning the client in question, we would forward the information to the Assessment and Collections Branch for their consideration. ...

Brian Ernewein, Director of the Tax Legislation Division at the Department of Finance, for his consideration. ...