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X sold all of his HOLDCO common shares to his children in consideration for promissory notes. ...

Nous pouvons néanmoins préciser que la présence physique d’un employé à un endroit afin d’y accomplir ses tâches habituelles constitue un facteur important à prendre en considération afin d’établir si cet employé se présente ou non à un établissement de son employeur. ...

However, based on the illustrative facts presented above, and taking into consideration the flexible tracing approach mandated by the Supreme Court of Canada in Ludco Entreprises Ltd. et al. v. ...

Generally, a plan will be considered to be a superannuation or pension plan where 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 and the contributions are to be used to provide an annuity or other periodic payment on or after the employee's retirement. ...

This case included consideration of an interest expense deduction under paragraph 20(1)(c) with respect to transactions that were entered into before the general anti-avoidance rule in section 245 became effective. ...

Because most of your concerns relate to tax policy, I am sending a copy of our correspondence to the Department of Finance, for their consideration. ...

As a result, based on our interpretation of the relevant provisions and taking into consideration the comments expressed by the courts in the FLSmidth case, we are of the view that all of the conditions of subsection 20(12) of the Act are met in this situation and therefore, the deduction under subsection 20(12) in respect of the U.S. tax paid by Taxpayer should be allowed. ...

Essentially, under these new provisions, the taxpayer will be required to pay tax at normal capital gains rates on capital gains realized on dispositions of flow-through shares whether the shares are sold for consideration or donated to a qualified donee. ...

I am therefore forwarding a copy of our correspondence to the Honourable Joe Oliver‚ Minister of Natural Resources, for his consideration. ...

In making such a determination, consideration should be given to the amount of severance that the taxpayer would have reasonably been entitled to under his or her contract of employment. ...