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In our opinion, as subparagraph 402(3)(a)(ii) of the Regulations includes only the salaries and wages paid by the corporation to employees, this precludes consideration of the deductions available to an employee under section 8 of the Act. ...

Our Comments Generally, the reasonableness of a reserve will be acceptable if in the calculation of the reserve, consideration is given to any mortgages assumed by a buyer in situations where the vendor has previously given a mortgage to a third party either at the time of acquisition of the land or to finance the cost of improvements to the land including construction of a building on the land. ...

Our understanding of the issue for consideration would appear to relate to the time of disposition referred to in paragraph 98(1)(c) of the Act vis-a-vis the time that a partnership ceases to exist as described in paragraph 98(1)(a) of the Act and the time of distribution of property of the partnership to its members. ...

Furthermore, as discussed in Interpretation Bulletin IT-339R2, a PHSP must contain the following basic elements: 1) an undertaking of one person, 2) to indemnify another person, 3) for an agreed consideration, 4) from a loss or liability in respect of an event, 5) the happening of which is uncertain. ...

Should you have a specific case under consideration we suggest that you request a ruling. ...

As mentioned in subparagraph 23(b) of IT-488R "Winding-up of 90%-Owned Taxable Canadian Corporations": Whether or not a property can be characterized as a capital property depends upon a consideration of the facts surrounding the acquisition of the property and the holding of the property by the subsidiary rather than by the parent. ...

Opco is under an obligation to pay its employees retiring allowances in certain circumstances in consideration of long-term services rendered to the company. 2. ...

Although you have not requested our comments thereon, some of the provisions of subsections 15(1), 56(2) and 245(2) may apply as a result of this type of transaction if the value of the shares received as consideration by Canco does not equal the value of the shares transferred. ...

A Canadian subsidiary sells its business assets to its Canadian parent and receives as consideration a non-interest bearing note receivable. ...

It would appear that this situation relates to an actual taxpayer and a factual situation that should be submitted to the appropriate district taxation office for their consideration. ...