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In other respects, the issue under consideration has already been addressed by our Division. ...

(d) The attribution rules do not apply if fair market consideration is paid for the property transferred and an election is made to not have the subsection 73(1) rollover apply. ...

Rather, the issued shares represent consideration for the employee surrendering their rights under the agreement. ...

However, any interest income earned on the investment of the CEP will be subject to general income tax rules, including consideration of the tax exemption in section 87 of the Indian Act. ...

Rather, the issued shares represent consideration for the employee surrendering their rights under the agreement. ...

Our Comments Acquisition Cost If a person becomes a partner by acquiring another partner's interest, the cost of acquiring the partnership interest will equal the fair market value of the consideration given for that interest, usually the purchase price. ...

In consideration of the Assignee making such payments, the Plaintiff agrees to settle his claims against the Defendants. ...

For example, where a taxpayer submitted reports to the government indicating the level of SR&ED activities in a previous year we would expect that this information would be a consideration of a subsequent year's capital funding and may result in a portion of such government funding as reasonably being considered to be in respect of SR&ED for purposes of subsection 127(18). ...

We have, as requested, forwarded your correspondence to the CPP/EI Rulings Division of the CRA for consideration of whether the caregivers are employees of your company. ...

However, the deductibility of such expenses is subject to any limitations in the Act on deductibility, such as the 50% rule in section 67.1 for food and beverages. 4) If an employee for whom training expenses are being paid by the employer is not dealing at arm's length with that employer, a determination will have to be made as to whether the training expense was reasonable taking into consideration all the relevant facts and circumstances of the particular case. ...