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Prepared by: Bruce Rankin ISSUE SHEET 1991 CPTS Roundtable Bruce Rankin Question 6 5-921639 June 12, 1992 This question was submitted by XXX,XXX The question asks the Department to indicate how it will treat taxpayers other than Gulf with respect to issues raised in the tax assessments under consideration in the Courts. ...

Submitted for your consideration. ...

Our Comments The Courts have described interest as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another". ...

XXX has also written to the Jonquiere T.C. in this regard and her letter has been passed to the Quebec D.O. for their consideration. ...

Should you disagree with our views in this matter we would suggest that you contact the Kitchener District Taxation Office for further consideration of these issues. ...

For example, subsection 110.6(7) of the Act may apply, depending on the facts of a particular situation, to deny a capital gains deduction claimed by a shareholder who is an individual in respect of the capital gain realized as a result of the application of paragraph 69(1)(b) of the Act because the corporation could be considered to have acquired its of shares for consideration that is significantly less than their fair market value at the time of acquisition, notwithstanding that the shareholder is deemed by paragraph 69(1)(b) to have disposed of his shares for proceeds of disposition equal to their fair market value. ...

We have attached a copy of correspondence received by this Division for your consideration and discussion with the department of Finance on the interpretation of paragraph 118.2(2)(e) of the Act with respect to stop smoking programs. ...

Should you wish to request an advance income tax ruling in respect of the transactions described above, we would be pleased to give further consideration to this situation. ...

As consideration for the transfer Y would receive a note equal to his ACB of the transferred shares and shares of Holdco having a value equal to the difference between the FMV and X's ACB of the transferred shares. 6. ...

Consideration would then be given to whether the paragraph 6(1)(a) benefit could be reduced under subsection 6(6) with respect to employment at special or remote work sites.  ...