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After further consideration, it is now our view, XXXXXXXXXX that the Act does not allow for an "imputed cost" and an "imputed income" to be deferred and amortized in accordance with the commercial practice as set out by CIPREC. ...

The Department will give consideration to a request that the amount taxed should not be subject to withholding tax a second time if, and when, a dividend is paid to that non-resident. ...

In this regard we would point out that the 1989 Corporate Management Tax Conference, question 8, dealt with the situation where a limited partner assumed the partnership's debt obligation as part of the consideration given for the acquisition of his partnership interest. ...

IT 448, paragraph 14, Q.23 1991 Round table and opinions given by Rulings (85 rollover of shares back to the issuing corporation results in a disposition of those shares, provided that consideration received in the form of other shares have different rights. ...

This is very important to ensure that those situations receive full consideration in the development of the guidelines. ...

In those jurisdictions which do not allow par value shares, the paid-up capital of shares of a given class will generally reflect the average of the consideration paid to the corporation for all of the issued and outstanding shares of that class. ...

Whether bona fide arrangements were made at the time a loan was made, for repayment within a reasonable period of time, is a question of fact that can only be determined upon consideration of all the circumstances of a particular taxpayer's case. ...

There are two other considerations which will affect the employer's ability to make such a contribution, however. ...

Section des particuliers et des entreprises de services le 12 janvier 1993 Question Est-ce que le montant de la pénalité prévue au paragraphe 163(1) de la Loi de l'impôt sur le revenu doit être calculé selon le montant brut du revenu non déclaré (avant l'application de toute déduction) ou selon le montant du revenu non déclaré après déduction d'éléments pouvant être déduits en vertu de la Section B de la Loi de l'impôt sur le revenu qui sont directement attribuables au fait de gagner un tel revenu et qui n'ont pas déjà été pris en considération? ...

In determining the reasonableness of a management fee the following would be taken into consideration: (a)     the nature of the services rendered and the time expended in performing those services, and (b)     the fees that would be paid to obtain similar services from other sources. ...