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We are also of the opinion that the same consideration may be extended to a corporation, for instance, the selects the Saturday closest to December 31 each year as its year end. ...

We also assume that the consideration given by B Ltd consists of preferred shares redeemable at the shareholder's option with a redemption price equal to the fair market value of the property transferred and a paid-up capital equal to the cost amount of the property. ...

As it is the responsibility of the Department of Finance to determine what is a qualified investment for a trust governed by an RRSP we have forwarded your letter to them for their consideration.  ...

The Department's position continues to be as stated in IT-239R2 that a capital loss arising from honouring a guarantee given for inadequate or for no consideration is nil by virtue of subparagraph 40(2)(g)(ii) of the Income Tax Act (the "Act"). ...

Copies of our correspondence with Rulings are enclosed for your review and consideration. ...

Subsection 148(7) of the Act applies where a corporation transfers a life insurance policy to a shareholder for no consideration but in our opinion that does not prevent the concurrent application of subsection 15(1) of the Act. ...

In the specific case we examined for the Hamilton District Office, it appeared to us that services rendered constituted the bulk of the contract and that the resulting design may have had little if any intrinsic value as it was unlikely to be useful to other clients. his would, of course, be a matter to be established on its facts and as we pointed out to the District Office, portions of the payments undoubtedly did relate to existing marketable "know-how" It may be of interest to note a taxpayer's comments on a similar engineering contract presently under consideration by one of our District Offices. ...

As yon may know, Canada taxes an a basis of residency, which is a question of fact that mast be decided by giving consideration to the particular circumstances of each case. ...

The cessation of the whole profit-making structure was the consideration given for entitlement to these grants. ...

In the circumstances, we suggest you send full details of bar claim for the consideration of the Winnipeg District Taxation Office. ...