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We would particularly draw your attention to the third precondition, the transfer must occur without consideration or benefit accruing to the donor or to anyone designated by the donor.   ...

As part of the consideration he receives a mortgage form the purchaser. 3.      ...

As a consequence we believe that favourable consideration should be given to 19(1)          request in this respect. ...

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. ...

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. ...

DEPARTMENT'S POSITION (a)     Whether bona fide arrangements are made for the repayment of a housing loan within a reasonable period of time at the time the loan is made is a question of fact which can only be determined upon consideration of all the circumstances of a particular situation.   ...

It also states that a payment made after December 20, 1991 that is otherwise a periodic payment would not be a periodic payment and thus subject to the full 25% Part XIII tax where, subject to certain exceptions, the total of all payments made under the RRIF at or before that time of the payment and in the year exceeds the greater of (a)     twice the amount that would be the minimum amount under the fund for the year, and (b)     10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of a fund as consideration under the fund had been transferred before the beginning of the year and the definition of "minimum amount" in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIF's. ...

In consideration for the partership paying these expenses, the other taxpayer agrees to pay to the partnership a percentage of its future income.       ...

Holloway   (613) 957-8953 Attention:  19(1) May 29, 1992 Dear Sirs: Re: Section 245(2) of the Income Tax Act (the "Act") This is in reply to your enquiry dated March 18, 1992, requesting our comments on a hypothetical situation whereby a farmer wishes to transfer farm property to an adult child at fair market value taking back a note as consideration.  ...

The foregoing represents the Department's present understanding of the law and does not take into consideration the recent decision of the Supreme Court of Canada in the Glenn Williams case (92 DTC 6320).  ...