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However, consideration should be given to whether subsection 104(2) of the Act could apply to deem multiple trusts to be a single trust. ...

In answering your question we have restricted ourselves to the consideration of the criteria referred to in your letter. ...

Such a distribution, being an action taken by the trustee in response to fiduciary duty, is one for which consideration cannot be exacted except in accordance with a provision in the trust deed. ...

Nonetheless, a determination in this regard would involve, in addition to the nature of the property, consideration of all other relevant factors including the intention and the conduct of the taxpayer in respect of the particular property. ...

Whether a support payment is taxable to the recipient and deductible by the payer depends only on whether the payment meets the requirements in the Act, which requires consideration of the court order or written agreement. ...

Consideration of such issues gives the CRA the opportunity to review or improve the tools currently in place, and to ensure we are always looking to improve the services that we provide. ...

I am therefore sending a copy of our correspondence to the Honourable Joe Oliver, Minister of Finance, for his consideration. ...

(d) As a result of the Division, FA2 transfers some of its assets (for no consideration) to FA3 and under foreign country corporate law, FA3 must issue shares to the shareholders of FA2 pro rata based on the number of shares they hold in FA2. ...

Given the broad variations in insurance policies and products, and that the terms and conditions of these types of contracts or arrangements are so flexible; such a determination would require a detailed review of the terms and conditions of the particular policy and consideration of all the relevant facts and circumstances pertaining to the particular situation. ...

Firstly, we would like to assure you that the arguments presented in your submission received careful consideration, however our position remains as previously stated. ...