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Facts Our understanding of the facts is as follows: 1.XXXXXXXXXX is a registered Indian. 2.XXXXXXXXXX lived off reserve for the years under consideration. 3. ...

Present discounted values are only relevant as regards the amount of the gift, which, as indicated in paragraph 5 of IT-226R, must take into consideration the fair market value of the property, the current interest rates, the life expectancy of any life tenants and any other factors relevant to the specific case. ...

Whether an expenditure should be viewed as being on a current or capital account is a question of law which entails the consideration of all relevant facts pertaining to the particular situation. ...

Jim Crandlemire, Chairperson of the PSHCP Board of Management, for his consideration. ...

The proposed divisive reorganization will involve the receipt by Canco of a deemed dividend under subsection 84(3) on the redemption of preferred shares of Newco which will be issued to Canco as consideration for the transfer of the real estate to Newco. ...

As noted in paragraph 4 of IT-334R2 "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. ...

., and receives 100 shares of Mergeco for nominal consideration, say $100. ...

Such a determination would be a factual one and would include consideration of whether the requirements set out in Income Tax Technical News No. 11 are met. ...

I note that you have already sent your letter to that department for consideration. ...

The children own the Class B interests, which were acquired for nominal consideration. 2. ...