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We understand that XXX As for judicial consideration of the meaning of the word “incurred”, Mr. ...

This matter has been brought to the attention of the Department of Finance for consideration of an appropriate technical amendment. ...

It would appear from our reading of the translation of the German decision that the German court considered that the vendor/licensor, not the purchaser/licensee, is the person upon whom the German VAT is imposed and who is liable therefore and that accordingly the VAT is included in the vendor's/licensor's income for income tax purposes as described in the first paragraph on page 2 of our Memorandum to you dated May 7, 1991, namely: "If, on the other hand, the VAT is a tax imposed on the vendor/licensor as the person primarily liable therefore (as opposed to merely being liable in its capacity as a collecting agent with an absolute obligation to collect), as appears to be indicated in the letter to you from the German competent authority dated August 17, 1990, we would be inclined to conclude that the entire amount payable to or for the account of the vendor/licensor or for which the vendor/licensor obtained credit against its VAT liability by virtue of action taken by the purchaser/licensee would be "consideration for the use of, or the right to use, any copyright, (etc.)... ...

In a butterfly where the transferee corporation ("Newco") issues voting preferred shares to Parcorp in consideration for the property transferred from Parcorp to Newco, the preferred shares may meet the requirements in 2(a) and (b) above, but will generally not be able to meet either (c) and (d), as the preferred shares will be taxable preferred shares. ...

Such determination will involve the consideration of corporate and commercial arrangements entered into by the taxpayer, some of which may not have been considered by Revenue Canada. ...

As explained in paragraph 3 of IT- 110R2 (Special Release), a gift, for purposes of sections 110.1 and 118.1 of the Act, is a voluntary transfer of property without valuable consideration. ...

Section 236 of the GST parallels section 67.1 of Act and is intended to limit the input tax credit that may be claimed in respect of the consideration payable for food, beverages or entertainment. ...

As stated in paragraph 3 of Interpretation Bulletin IT-339R2, the PHSP must contain the following basic elements: (a) an undertaking of one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

Our Interpretation Bulletin IT-419 is enclosed for your consideration in this regard. ...

It is our opinion that the particular provisions must be read in their context and interpreted with due consideration given to the purpose of both the provision and the treaty as a whole. ...