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There may be other relevant considerations where consolidated returns are filed in other jurisdictions- particularly the United Kingdom. ...

Is the dividend to be calculated on the value of the shares when they are transferred or the consideration received when they were issued? ...

As your concerns relate to tax policy, which is the responsibility of the Department of Finance, I have forwarded a copy of your correspondence to Finance officials for their consideration. ...

As such the "interest" component would be part of the purchase price, rather than consideration for money due, owing to or belonging to the vendor. ...

However, these are separate issues from the issue under consideration involving the characterization of active business income in a two-tier partnership and the answer given at the 1991 Roundtable is so restricted. ...

If the parties decide to proceed and provide us with the necessary documentation we would be pleased to reopen the file and give it priority consideration. ...

Response A determination of whether a corporation is constituted exclusively for the purpose of providing low-cost housing accommodation for the aged in a particular taxation year involves both a consideration of the corporation's enabling documents and of the nature of the activities carried on by the corporation in the year to ensure that the corporation has not since adopted other purposes. ...

We have therefore taken this opportunity to refer this issue to our Publications Directorate for their consideration when they issue any revisions to the Bulletin. ...

XXX IT-239R2 discusses the deductibility of capital losses from guaranteeing loans for inadequate consideration and from loaning funds at less than a reasonable rate of interest in non-arm's length circumstances. ...

Factors that were taken into consideration in determining whether we would want to take the position that XXX and XXX were not carrying on active businesses are that the tax potential is minimal and that the taxpayer, XXX does not appear to be obtaining any undue or unintended Canadian tax advantage. ...