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It is therefore the legal character of amounts that determines their Part I.3 tax treatment although we recognize that accounting terminology must be given consideration in this regard. ...

Please send any additional information concerning this matter to XXXXXXXXXX at the XXXXXXXXXX Tax Centre for further consideration. ...

Flaherty, Minister of Finance, for his consideration. I trust that the information I have provided clarifies the CRA’s position on this matter. ...

This loss may be denied pursuant to subparagraph 40(2)(g)(ii) of the Act unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...

The amount or value of any prize or award received by a distributor or retailer from the provincial lottery corporation is considered to form part of the consideration received for selling lottery tickets and, as such, should be treated as business income of the particular distributor or retailer. ...

Consideration will be given by the CRA to whether any pre-section 212.3 cases involving foreign affiliate dumping could be challenged under existing anti-avoidance rules, including section 245. ...

As noted in the Minister's response of October 28, 2013, your comments about the clarity of the CRA's publications and frontline services have been forwarded to the responsible CRA officials for their review and consideration. ...

Reasons: In light of the variety of interests that could be granted as consideration for the farmee's undertakings, it is appropriate to consider any particular interest that is to be granted in the context of an individual advance income tax ruling application and according to the historical basis for the administrative treatment. 2012 Canadian Petroleum Tax Conference Question 4-- Farmout Arrangements The CRA's longstanding position on farmout arrangements which do not give rise to proceeds of disposition to the farmor is set forth in IT-125R4, paragraph 14. ...

Therefore, I am sending a copy of our correspondence to the Honourable, Bill Morneau, Minister of Finance, for his consideration. ...

In addition, our comments below do not take into consideration the consequences of any deemed dispositions that may occur as a consequence of death. ...