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We are of the opinion that the location of the location of the "business" of the taxpayer would be one of the major considerations in determining the rate of investment tax credit for the owner of a vessel. ...

In our telephone conversation of July 31, 1990 you stated, as a point of clarification, that one of the changes under consideration was a change from an ordinary life plan to an adjustable single premium life plan. ...

The relevant facts of the case under consideration, the reasons that a favourable ruling was originally given and the opposing Corporate Reorganizations Section position are set out in the attached copy of Leasing and Financing Section's submission to the Review Committee. ...

In formulating our reply as outlined above, consideration was not given to other provisions of the Act, such as section 84.1, which may apply in a specific situation involving the disposition of shares. ...

It is therefore a question of fact whether any or all of the refinery piping under consideration in this instance can be regarded as a conduit and therefore as includable in Class 2. ...

Accordingly, in our view, where the fair market value rental does not provide a reasonable return on the value or the cost of the property, the amount or value of the benefit being conferred on the shareholder is more indicative of the true value of the benefit when it is determined by a normal rate of return on the greater of the cost or the fair market value of the corporate asset plus the operating costs, less any consideration paid to the corporation by the shareholder. ...

The comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of specific transactions. ...

Requests made on behalf of specific taxpayers pursuant to paragraph 85(7.1)(b) should be directed to the relevant district office for consideration. ...

This warranty was an integral part of the consideration given for the price the purchaser agreed to pay. ...

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. ...