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QUESTION The "old" flow-through share rules are contained in subparagraph 66.1(6)(a)(v) which states that Canadian exploration expense ("CEE") of a taxpayer means any expense incurred after May 6, 1974 that is: (v)      any expense referred to in any of subparagraphs (i) to (iii.1) incurred by the taxpayer pursuant to an agreement in writing with a corporation, entered into before 1987, under which the taxpayer incurred the expense solely as consideration for shares, other than prescribed shares, of the capital stock of the corporation issued to him or any interest in such shares or right thereto, Where a limited partnership enters into a flow-through share agreement with an exploration corporation, the reference to the "taxpayer" in subparagraph 66.1(6)(a)(v) is to the limited partnership. ...

(see q. 22 attached)  I wish to bring to your attention a somewhat similar position taken at the 1990 Round Table, concerning loan guarantee's from non-residents for no consideration.  ...

However, we feel that the following issues does need careful consideration:-     where beneficial ownership resides, and-     whether transactions are subject to general anti-avoidance rules. ...

To determine if in a particular situations such relief is available, a taxpayer would have to submit full details to his local District Taxation Office for consideration. ...

For example if the donor were to receive services or any valuable consideration in exchange for the restrictive covenant there would be no gift for purposes of the Income Tax Act. ...

L'appareil en question (l'«Appareil») est utilisé dans votre entreprise 24(1) et permet de recueillir les données sur le terrain (angles et distances), de les réduire à l'horizontale, de les traiter en prenant en considération la pression atmosphérique et la température, de calculer les coordonnées en trois dimensions (x,y,z) et de retransmettre lesdites données à un micro-ordinateur. ...

This is not the case in the situation under consideration. It is also apparent, from the information provided, that the individual purchaser of the automobile will receive these payments only by virtue of their status as employees of 24(1) (i.e., the individual would not be entitled to these payments if he were not employed at a participating employer).  ...

(c)       One of the conditions for consideration for an assignment is that the employee has demonstrated a potential for advancement to senior positions. ...

For instance, if the individual in the hypothetical situation were to transfer his shares of Holdco to Newco, receiving from Newco newly issued shares as consideration for the shares of Holdco, the shares of Newco would be viewed as being shares substituted for the individual's shares of Holdco. ...

In order for a particular DRDP to qualify as a PHSP, as defined, the plan implemented by an employer on behalf of its employees must be in the nature of insurance and must contain the following elements as set out in paragraph 3 of IT-339R2: (i)     an undertaking of one person,  (ii)     to indemnify another person, (iii)      for an agreed consideration, (iv)      from a loss or liability in respect of an event, (v)      the happening of which is uncertain. ...