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We have reviewed your submission with respect to the 24(1) plan in this light and have passed our comments on to the Halifax District Office for their consideration. ...

Sider (613) 995-1178 February 8, 1983 Dear XXXX We are writing in response to your letter of December 2, 1982 wherein you requested our comments concerning subsection 85(1) elections where the transferee corporation cannot immediately issue the shares as part of the consideration for the transfer of property. ...

Where at a particular time an agreement relating to a share of the capital stock of a corporation is entered into or modified the fair market value of the unissued share at the particular time, for purposes of clauses (a)(i)(A) or (e)(i)(A) of the above definition, is a determination of fact which can only be made with consideration to the specific circumstances. ...

Accordingly, we are referring this enquiry to you for your consideration and direct reply. ...

The Ontario Ministry of Revenue will be provided with the information necessary for their consideration of a remission of provincial income tax. ...

Tel que suggéré par le centre fiscal, nous vous soumettons ces documents pour votre considération afin que vous en teniez compte lors d'une éventuelle révision du bulletin d'interprétation IT-519, notamment les paragraphes 23 et 24 dudit bulletin. ...

However, we have sent a copy of the relevant adverse decision material to Publications Division for consideration during the next "regular" revision of the bulletin. ...

We have forwarded a copy of your letter and of our reply to our Current Amendments Division suggesting they bring the matter to the attention of the Department of Finance for consideration for inclusion in a technical bill. ...

Department's Position As indicated in paragraph 7 of Interpretation Bulletin IT-436R, it is generally our view that where a vendor disposes of a noted receivable from a purchaser of a capital property to a third party in consideration for a promissory note of that third party, a capital gains reserve under subparagraph 40(1)(a)(iii) is no longer available because there is no longer anything due to the vendor from the purchaser in the original transaction. ...

If you cannot locate a copy of the agreement we would suggest you contact the financial institution and obtain a copy of the master agreement which sets out the terms of the arrangement under which your IRA was issued, and submit the same to us for consideration. ...