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We are therefore referring this matter for your consideration. We have asked XXXX to submit a copy of the trust documents so that we may be in a position to reply to the questions on page 2 of her letter. ...

To this extent, the calculation of "capital" reflects paid-up capital considerations. ...

Szeszycki (613) 957-2103 19(1) January 18, 1990 Dear Sirs: Re: Payments to Foster Parents We are responding to your letter of September 18, 1989 addressed to the District Taxation Office in Vancouver which was forwarded to this office for consideration and reply. ...

We prefer to answer questions about the tax consequences of a proposed plan in the form of an advance income tax ruling taking into consideration all the facts including the terms of the plan and any other relevant agreements. ...

Although we leave the final determination in your hands, we are providing the following comments for your consideration. ...

Harding (613) 957-3499 19(1) January 23, 1990 Dear Sirs: Re: Employee Share Purchase Plans This is in reply to your letter of November 15, 1989 wherein you requested our consideration of a proposed model share purchase plan. ...

This change, if adopted, is expected to be applicable for 1986 and subsequent year and therefore could eliminate the inequity you have noted in the case of XXXX if he pays the amount in the year he received it or within 60 days after the end of the year to a carrier as consideration for a RRIF under which he would be the annuitant and he designates such an amount in his return of income for the year. ...

The study report you have submitted for our consideration presents an approximation of such value. ...

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

It is necessary to determine at the inception of the agreement whether the object of the agreement and the consideration being paid, is in reality transferring the ownership in the property from one party to another. ...