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We offer the following comments for your consideration: I. Directive l. ...

Although such a determination can only be made after an examination of all the facts and consideration of the above criteria it would appear based on the limited information provided that the Indian in your fact situation had his principal place of business in his home. ...

In determining whether a loan was made by virtue of an office or employment, the Department will take into consideration any involvement or assistance by his employer in obtaining the loan, including (a) involvement in negotiation of the loan, (b) guaranteeing repayment of the loan principal or interest, (c) recommending in writing to the lender that the loan be made, (d) agreement in writing before the loan is made, to assist with the cost of the interest either by direct reimbursement to the borrower for all or part of it or by paying such interest directly to the third party lender, or (e) providing the individual with a letter of introduction to a mortgage lender explaining the amount and terms of the mortgage interest subsidy which the employer will be making to the employee. ...

., COMPAGNY LAW CONSIDERATIONS RELATING TO CORPORATE ACTIONS AND REORGANIZATION, 1976 Conference Report, p. 235. *3- Ibid, page 237, note 100 ...

The adjusted cost base of the remainderman interest would be the holder's original purchase price or deemed purchase price, as the case may be, adjusted for any subsequent acquisitions of a life interest acquired for consideration prior to the death of the life interest holder. ...

The key consideration is that the reimbursement pertains to the "same use" and timing of the payment of the reimbursement is not relevant to determining whether the allowance is required to be included in income. ...

As consideration for such purchase, Company A issues Class A special shares. ...

.'s producing properties were disposed of to its subsidiary for consideration that included interest bearing notes receivable. ...

The opinions expressed in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

If, however, the hospital pays the settlement grant prior to the individual becoming an employee, the payment would be taxed under subsection 6(3) of the Act as having been received as full or partial consideration for accepting the offer of employment. ...