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Gerry Lalonde as soon as possible so that consideration can be given to an appropriate amendment to the Act. ... Assuming that one of the main purposes of the loan may reasonably be considered to be to reduce the income of the individual and to benefit a "designated person" (as defined in subsection 74.5(5) of the Act) in respect of the individual (after consideration of the provisions of subsection 74.4(4) of the Act) then a calculation pursuant to subsection 74.4(2) of the Act will be required for any taxation year in which the loan was outstanding to determine the amount that is deemed to have been received as interest in the year by the individual. ...

Essentially, the issue in respect of the particular case here under consideration is the date at which the seller and buyer intended that title to the equipment passed to the buyer, having regard to the fact that the equipment was not in existence on the date the agreement of sale was entered into, but was to be (and was) subsequently manufactured by the seller. ... It is submitted that in the case here under consideration, 24(1) So far as we can determine from the materials you provided to us, 24(1) Variation in Exchange Rate Before Date of Acquisition So far as we have been able to determine, there is no case law or statutory guidance as to the treatment of variations in the exchange rate before the date of acquisition of the property. ...

Prendre en consideration le 10 000 $ deja excédentaire et etablir ainsi l'excédent pour 1'annee a 15 000 $ imposable a 10%. ... Retenir un impôt de 5 sur les 5 000 $ ne prenant pas en consideration les autres retraits pour llannée. ...

First, the application or non-application of a plan provision should not be based solely on the considerations of Revenue Canada, Taxation, particularly when alternative courses of action based on that consideration are not clearly detailed in the plan. ...

If such a guideline is to be maintained, we suggest that any period over a month be reviewed on an individual basis to take into consideration such factors as the industrial practice (i.e. offshore drilling personnel usually work 30 days on and 30 days off), the nature of the work performed, and the remoteness of the work site from any established community, etc. ... We have also suggested other minor editing changes to the draft IC for your consideration as noted thereon to add clarity to the subject matters at issue. ...

Where, however subsection 191(4) of the Act is applicable, and one of the price adjustment mechanisms mentioned previously becomes operative due to an overstatement of the fair market value of the consideration for which the preferred shares were issued, the full amount of the original deemed dividend may be subject to tax under Parts IV.1 and VI.1 if the aggregate amount specified for purposes of subsection 191(4) exceeds the revised fair market value of the consideration for which the preferred shares were issued. ...

The characterization of the SAR will become more important where the lender is a non-resident, as withholding tax considerations may arise. ... With respect to withholding tax considerations, we again would have to review specific documentation. ...

We also offer a number of suggested changes for your consideration. These are summarized below and are also written on the draft. 1. ... Consideration should be given to including the incorporation date for Opco as it would eliminate any concerns regarding the impact of V-day on the operation of paragraph 84.1(2)(a.1). 5. ...

Adler (613) 957-8962 February 22, 1990 Dear Sirs: This is in reply to your letter dated January 12, 1990 in which you requested clarification of this Department's interpretation of "any group of employees" as used in paragraph (d) of the definition of "designated shareholder in subsection 4901(2) of the Income Tax Regulations ("Regulations"), and provided the following two examples for our consideration. ... Wilson, Minister of Finance, we suggest that you pursue your concerns on this issue by writing to relevant officials in his Department for their consideration. ...

In the third paragraph of our October 30 letter we stated: In our opinion, where an insurance company accepts an annuity contract as partial consideration for the assumption of another party's obligation with respect to an out of court settlement, the insurance company would be required to include in income, in the year the annuity contract is received, an amount equal to the aggregate of the fair market value of the annuity and the other consideration pursuant to section 9 of the Income Tax Act (the "Act"). ...