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En conséquence, nous vous transmettons ladite demande du Bureau de district de Montréal pour votre considération. ...

You requested our comments whether losses arising from loan guarantees given by the above corporation on behalf of U.S. corporations which it controls, for no or inadequate consideration, would be deemed to be nil by subparagraph 40(2)(g)(ii) of the Income Tax Act (the "Act") on the basis that the guarantees were not given for the purpose of gaining or producing income. 21(1)(b) Accordingly in our view 24(1) The exception in paragraph 6 of IT-239R2  and paragraph 7 was established to address specific tax policy concerns.  ...

To obtain a definite answer to your query, we suggest you submit your pension plan to your District Office for their consideration. ...

Since this enquiry is in respect of a factual situation, we are forwarding it for your consideration and reply. ...

In determining whether the costs of a particular renovation can be deducted against income in the year or require capitalization, consideration should be given to the guidelines in paragraph 4 of interpretation bulletin IT-128R "capital Cost Allowance- Depreciable Property", a copy of which is enclosed. ...

Should you have an actual case under consideration we suggest that you request a ruling.  ...

Hillier A/Director F-3249 Paragraph 48(1)(a) Elections- F-3249 Prescribed Form We have the following comments for your consideration which we discussed via the telephone on September 11: (1)       In the first paragraph you have the taxpayer electing immediately before ceasing to be resident. ...

The comments set out in this letter are of a general nature only and do not take into account considerations that might arise in the context of specific transactions or events.  ...

The notable example related to drilling rigs, although another case which is under consideration is one involving consultants and space being available in the offices of the hiring party in Canada. ...

We agree with your conclusion to disallow the application of subsection 85(1) of the Act to the sale of the building to 24(1) in 1985 on the basis that the relevant shares to be given as consideration were never authorized or issued.   ...