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DEPARTMENT'S POSITION There would be several factors that would have to be taken into consideration in deciding whether it was "reasonable to conclude that the property was acquired by the taxpayer to replace the former property. ...

Paragraph 4 of Interpretation Bulletin IT-334R2 gives the following explanation concerning "Gifts and Other Voluntary Payments": "Amounts received as gifts, that is, voluntary transfers of real or personal property without consideration, are not subject to tax in the hands of the recipient. ...

However, consideration may be given as to whether the amounts paid for part-time attendant care would qualify as a medical expense under paragraph 118.2(2)(b.1) of the Act. ...

Usually no additional consideration is payable on the exercise of the Special Warrants and any Special Warrants that are not redeemed or exercised by the expiry date are deemed to have been exercised in full at that time. ...

However, it should be noted that in applying subparagraph 5(a) of Article 13 of the Convention, consideration has to be given to property referred to in paragraph 4 of Article 13 of the Convention, whether or not such property is property in which the business was carried on. ...

You may however provide the details of such situations to your local Tax Services Office for their consideration and comment. ...

., 81 DTC 8 (TRB) for consideration of whether a right to income is vested.) ...

In order that an association or organization may obtain "approved" status, it is necessary that certain information and documents in respect of the association be submitted to this Department for consideration and approval. ...

Principal Issues: Whether steam producer or vendor would, in determining the Class 34 heat rate standard of 7000 BTU/kWh or less, take into consideration the steam host's use of steam? ...

The interpretive positions adopted by the Department are the result of the careful and detailed analysis of jurisprudence relative to the types of situations under consideration. ...