Search - consideration

Previous versions did not consider the fact that subparagraph 40(2) (g)(ii) consists of two parts: (a) a debt acquired for the purpose of gaining or producing income from a business or property (other than exempt income), (b) a debt acquired as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm's length. ...

6 December 1989 Income Tax Severed Letter DEC 6 1989 XXXX This is in reply to your letter of August 16, 1989 and your follow-up memorandum of November 9, 1989 in which you request our consideration of your entitlement to the $500,000 capital gains exemption with respect to the sale of the XXXX Our Comments We have examined the documentation submitted with your letter and we note, as you suggest, that payments on the purchase price were made in 1987, 1988 and 1989, with the unpaid balance paid on XXXX We also note that these payments, as a condition of the Memorandum of Understanding, were not paid directly to you but were to be held by XXXX in trust on account of the agreement entered into pursuant to the Memorandum of Understanding. ...

A copy of your reply was forwarded to this office for our review and consideration. ...

Oulton (613) 995-1787 XXXX Dear Sirs: This is in reply to your letter of January 29, 1982 wherein you requested our consideration of your views in the following hypothetical situation: 1. ...

Toyota 995-1717 Sale of Undivided Interest upon Cessation of Partnership We have reviewed your memorandum of March 31, 1960 and the agreement submitted and offer the following comments for your consideration: 1. ...

I have, therefore, forwarded a copy of this correspondence to the Honourable Michael Wilson, Minister of Finance, who is responsible for legislative amendments, for his consideration. ...

Thank you in advance for your consideration of these issues. As you know, we are currently in the midst of our annual personal tax preparation work and, therefore, we would appreciate a response at your earliest convenience. ...

Should you require an opinion on the value of the amount of the loan forgiven, full particulars should be forwarded to the local District Office (Business Equity Valuation Unit) for consideration. ...

The question of whether a person is a resident of Canada is one of fact that must be decided by giving consideration to the particular circumstances of each case. ...

In this connection, paragraph 6 of Interpretation Bulletin IT-239R2 sets out the circumstances and conditions under which a loss resulting from, among other things, the payment of a debt under a guaranty for which the guarantor received insufficient consideration, is not considered by the Department as a nil loss under subparagraph 40(2)(g)(ii) of the Act. ...