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Where a taxpayer has accrued and reported interest income on a debt obligation and has at any particular time disposed of that obligation for consideration equal to its fair market value at the time of disposition, the taxpayer may, by virtue of subsection 20(21) of the Act, deduct in computing income for the year of disposition, the amount, if any, by which the aggregate of the amounts of interest from that debt obligation that was included in the taxpayer's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...

As was the case with the comments made during the 1988 Round Table, the comments made in this letter are purely of a general nature and do not take into account considerations that might arise in the context of a specific transaction or event.  ...

If you have a factual situation in mind, you may wish to provide full details to the local district taxation office for their consideration. ...

In addition, the enclosed Information Circular 87-2 will have some importance when filing the T2 Return since it discusses transfer pricing methods and consideration. ...

The following is a statement of our general view on the meaning of the term "ordinary  course of business" as announced at the 1984 Canadian Tax Foundation Conference, which may be helpful to you:      Factors that we have considered in establishing whether particular shares were or were not acquired in the ordinary course of business are as follows: 1)     the nature of the holder's activities; 2)     the number and frequency of such share acquisitions by the holder; 3)     whether the funds involved represent the initial capitalization of an new subsidiary or the provision of additional operating capital to a subsidiary, both of which would normally indicate permanent capitalization; 4)     the terms of the shares acquired and their status as "term preferred shares" otherwise than by virtue of control of  the issuer by specified financial institutions; and 5)     whether the shares were acquired as consideration on the sale of a business or part of a business where the holder's business has not previously included such transactions. ...

We offer the following comments for your consideration: 1.     Re:  "Summary" Inserting a)     "factually resident in Canada or they may be " after "may be" (line 3); b)     a period after "Canada" (line 3);and c)     "Both factual and deemed residents of Canada are" after "and thus" (line 3) and deleting "and thus" (line 3) may provide greater clarity. 2.      ...

Thus in your hypothetical situation it is the shares (and not the underlying assets) of the subsidiary which would be taken into consideration in determining whether the all or substantially all test in the definition of small business corporation in subsection 248(1) of the Act is met. ...

The amount of reduction available would be based on the facts and circumstances surrounding each case (with consideration being given to the frequency and degree of loss of privacy and quiet enjoyment, for example). ...

The comments expressed 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. ...

We understand that 24(1) 23 As for judicial consideration of the meaning of the word "incurred", Mr. ...