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The scenario under consideration involves a child (the "Child") and her separated parents ("Individual A" and "Individual B"). ... We would generally expect that each parent obtain a receipt from the caregiver for his or her share of the child care expenses paid by the parent; however, the circumstances under consideration are somewhat different because Individual B is paying the caregiver for child care services provided to the Child in respect of Individual A and herself and is receiving a reimbursement of 60% of the costs from Individual A. ...

The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. ... Question 4 With consideration of the information in Q3, paragraph 8 states that medical and health insurance plans offered by Blue Cross qualify as PHSPs. ...

By entering into leases with its customers for new farm equipment and coincidentally assigning them and the farm equipment to the manufacturers for full consideration, the dealer is engaging in the sale of inventory. ... By entering into leases with its customers for new farm equipment and coincidentally assigning them and the farm equipment to the manufacturers for full consideration, the Dealer is engaging in the sale of inventory. ...

Your letter also stated that the Regional Municipality whose jurisdiction includes the land under consideration will not allow further subdivisions on that particular acreage. ... As a final consideration, in granting the surface lease, it is likely that the taxpayer has had a partial change in use of the property from personal use to income-producing (see paragraph 30 of IT-120R5). ...

The last paragraph of Paragraph 73 is amended to read as follows: " As consideration for the transfers of property described above, each Sibling will issue to its respective Holdco a non-interest-bearing demand promissory note with a principal amount equal to the FMV, on the Determination Date, of the XXXXXXXXXX Shares transferred to the Sibling in the transfers described in this Paragraph. ... The penultimate paragraph of Paragraph 74 is amended to read as follows: " As consideration for such sales, Father will pay cash or issue a non-interest-bearing promissory note (payable according to its terms) to each Sibling in an amount to be agreed upon among Aco, Father, the Siblings and the Holdcos prior to the transfers of property to the Siblings' Subs described in Paragraph 68 above, which amount will be equal to their best estimate, on the Determination Date, of the aggregate amount of the tax liability of such Sibling and such Sibling's Holdco referred to in this Paragraph. ...

The consideration for the transfer will be cash. 18. Parentco immediately after the transfer described in paragraph 17 will contribute all the issued and outstanding shares it holds in Forco1 to a wholly owned subsidiary, a XXXXXXXXXX corporation, for FMV. The consideration will be the shares of such subsidiary. For the purposes of this ruling, the transfers of the Forco1 shares described in this paragraph and paragraph 17 will be referred to collectively as the "Transfers" and individually as a "Transfer". ...

Question 8 If a taxpayer's involvement in a venture is motivated by tax considerations, will this be viewed as a personal element such that it could affect the determination of whether the activity has a sufficient degree of commerciality to be considered a source of income under the Act? Response 8 If a taxpayer is motivated by tax considerations when he or she enters into a business or property venture, this will not detract from the venture's commercial nature or characterization as a source of income under the Act. ...

In general, for Canadian tax purposes, an arrangement is a pension plan if contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee or, in some cases, where amounts have been contributed by a government. ... While you have not requested this information, we offer the following comments for your consideration. ...

" (The Net Profits Interest in the Oil and Gas Industry- An In-Depth Analysis), Canadian Petroleum Tax Journal, Vol. 1, 1988: An NPI can arise in essentially two ways: one party conveys away or disposes of a 'Canadian resource property' and takes back the NPI as consideration therefor or, alternately, carves-out the NPI from an interest he continues to hold and conveys it to another, perhaps for geological services or even simply for a cash payment. In either case, once created, an NPI can be transferred to a third party for consideration. ...

In the event that the share consolidation results in a shareholder owning a fraction of a post-consolidation Pubco1 share (for example, assume 1050 pre-consolidation Pubco1 shares will be replaced by 10.5 post-consolidation Pubco1 shares), Pubco1 will pay the shareholder an amount not exceeding $200 as consideration for the shareholder's fractional (0.5) Pubco1 share. ... Since you believe that the 116 clearance certificate requirement would impose a practical burden on Pubco2 non-resident shareholders, we will forward a copy of this letter to the Department of Finance for their consideration. ...