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XXXXXXXXXX also indicated that the Foundation is now considering retaining ownership of heritage property transferred to the Foundation for no consideration and entering into long term contracts with third parties for the maintenance, upkeep, safeguard and use of such property. ...

In this regard, I note that you have already sent a copy of your letter to the Minister of Finance for consideration. ...

As the Department of Finance is responsible for making amendments to the Income Tax Act, and a copy of your letter was also sent to the Honourable Paul Martin, Minister of Finance, I am certain your views will receive every consideration. ...

This is not the case with respect to the situation under consideration. ...

I trust he will give your comments every consideration. I appreciate the opportunity to respond to your concerns. ...

Reasons: Taxability/deductibility was a consideration in deciding the amount of the Payments by the parties and the courts, prior to the "new rules". ...

As you have already relayed these concerns to the Honourable Paul Martin, Minister of Finance, in a letter of April 14, 1998, I am certain your views will receive every consideration. ...

Subject to subsection 51(4) of the Act, section 51 will apply to any situation where a share of the capital stock of a corporation is acquired by a taxpayer in exchange for a capital property that is another share of the particular corporation and no other consideration is received for the old shares. ...

In any revised draft of this paper, consideration will be given to the comments and suggestions received from interested industry participants, and from consultations with officials at both CAVCO and the Department of Finance. ...

In this case, the cost of the property received by the annuitant from the RRSP will be the FMV of such property (which also equals the FMV of the property given up as consideration for such property). ...