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As a result, the mutual fund corporation shares received by the partnership in exchange for the cash would not be received from the mutual fund corporation as consideration in respect of any disposition to which subsection 85(2) of the Act applied. ...

Nous soumettons ce dossier pour votre considération. Directeur intérimaire Division des services bilingues et des industries d'exploitation des ressources Direction des décisions ...

While you have provided comments which are relevant to the determination of "misuse" or "abuse" we do not feel such a determination can be made without full consideration of the specific circumstances. ...

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. ...

" Accordingly, in the situation you have described, it is the corporation's proportionate share of the fair market value of the underlying assets of the partnership that is taken into consideration in determining if the previously mentioned requirement in the definition of "small business corporation" has been satisfied. ...

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. ...

In considering the situation described above, no consideration has been given to other tax consequences that may be relevant to the particular situation. ...

The amounts of any such renunciations cannot exceed the consideration paid for the option. ...

We regret that we are unable firmly to opine on the situations submitted for our consideration since determinations of this nature are conditioned by the circumstances of a particular case and would therefore be best considered in the context of an advance income tax ruling where full disclosure of all material facts is of course necessary. ...

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). ...