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Provided that the child acquired this interest without consideration, it is our view that subsection 148(8) would apply to the transfer of the policy from the parent to the child, such that the deceased parent would be deemed to have disposed of the policy, immediately before the transfer, for proceeds of disposition equal to the adjusted cost basis of the policy to the parent, and the child will be deemed to have acquired an interest in the policy at a cost equal to those proceeds. ...

Reductions of interest rates given in consideration for reductions in annual club dues are subject to taxation. ...

Since changes to the kilometric rates are the responsibility of the TBS, I am sending a copy of our correspondence to the Honourable Scott Brison, President of the TBS, for his consideration. ...

Donald Drummond, Assistant Deputy Minister, Tax Policy Branch, Department of Finance, for his consideration. ...

In this respect, we have included two booklets for your consideration. ...

Subsection 146.3(1) of the Income Tax Act (the “Act”) defines retirement income fund as an arrangement between a carrier and an annuitant under which the carrier agrees to make payments to the annuitant and, if elected by the annuitant, to the annuitant’s spouse after the annuitant’s death, in consideration for the transfer of property to the carrier. ...

Under the terms of the agreement, the taxpayer will pay a sum of money to the taxpayer's spouse as consideration for the spouse agreeing to waive any entitlement the spouse has under Part 3 of the Family Relations Act of British Columbia. ...

If the fact situation described in your aforementioned letter relates to specific transactions and taxpayers, we would be pleased to give further consideration to this matter in the context of an advance income tax ruling. ...

Position: Favourable consideration may be given in certain situations. ...

After giving due consideration to the information submitted, we are unable to provide a definitive response to your questions without further details of the particular case, as it will depend on the terms of the particular trust indenture, the type of trust, the accounting and tax practices with respect to income and the rights of the beneficiary of the trust to enforce payment in respect of the income of the trust. ...