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With respect to the question of a "reasonable" allowance under the proposed amendments, it is our tentative view that such questions will be determined on a case by case basis, taking into consideration each employee's circumstances. ...

The comments expressed 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. ...

Common shares of HOLDCO are received as the only consideration. 3. The common shares of OPCO are converted on a tax-free basis under section 86 of the Act into preferred shares of OPCO having a fair market value and paid-up capital equal to the fair market value and paid-up capital of OPCO's common shares. 4. ...

Consideration will be given to revising Interpretation Bulletin IT-341R to reflect the above. 2. ...

As indicated in paragraph 3 of our Interpretation Bulletin IT-110R2, a gift for purposes of paragraph 110(1)(a) of the Income Tax Act (the "Act") is a voluntary transfer of property without consideration or benefit of any kind accruing to the donor or to anyone designated by the donor. ...

Where the surviving spouse reaches a settlement with the executors and beneficiaries of the estate that property in the deceased's estate will be transferred to the surviving spouse in consideration of a release of his or her rights to make a claim under the FLA for an equalization of net family property, it is our view that the transfer would not be considered a transfer as a consequence of the death of the deceased. ...

" Thus in the circumstances of your question it is the corporation's proportionate share of the fair market value of the underlying assets of the partnership, in addition to all of the other assets of the corporation, that is taken into consideration in determining if the 90% requirement set out in the definition of "small business corporation" in section 248, is met and, by extension, if the same requirement in the definition of "qualified small business corporation share" in section 110.6 is met. ...

A determination of the reasonableness of the amount of remuneration paid to any particular employee requires consideration of the duties performed by the individual, as well as the time spent in carrying out those duties. ...

The comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

Your letter has been referred to this Directorate for our consideration and reply. ...