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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. ...

., net of assistance, to a person who has given consideration under an agreement to a corporation for the issue of a flow through share of the corporation. ...

The problem arises if the funds are received earlier and since we doubt that this result was intended we shall draw it to the attention of the Department of Finance for consideration. ...

We are therefore once again submitting our views on this matter and would request that further consideration be given by you. ...

Department of National Revenue response Whether a taxpayer would like to confer a benefit on a related person is a question of fact that can be determined only after consideration of all the relevant facts in the situation. ...

Thus it is part of the consideration provided by the taxpayer, as are the individual swap payments that he has undertaken to make, but it is not to be confused with or regarded as a prepaid portion of those payments. ...

Again, consideration should be given to the exception provisions of paragraph 212(1)(h) of the Act. ...

To determine the tax treatment of the realization of discounts on long-term securities held for short periods prior to maturity by manufacturing and merchandising corporations consideration must be given to the application of subsection 39(4) of the Act and to the comments contained in IT-114 entitled "Discounts, Premiums and Bonuses on Debt Obligations. ...

You describe a situation where a partnership between an individual and a holding company intends to sell in an arm's length transaction its only significant asset, a rental property, for a consideration consisting of the assumption of the existing mortgage by the purchaser and the issue of a second mortgage. ...