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As all these issues are dependent on the facts particular to your situation, we have forwarded your correspondence to Harvey Beaulac, Acting Director at the Ottawa District Taxation Office, 360 Lisgar Street, Ottawa, Ontario, K1A 0L9 for consideration and reply. ...

However, in a situation involving taxpayers which deal at arm's length for the purposes of the Act, it is our view that where, in consideration for earning an interest in a resource property for which no proven or probable mineral reserves have been established, an expense is incurred by a taxpayer in the course of drilling for the purpose of determining the existence, extent or quality of a mineral resource, such expense would represent CEE of that taxpayer under paragraph (f) of the definition of that term contained in subsection 66.1(6) of the Act provided that such expense is not Canadian development expense and cannot reasonably be considered to be related to a mine that has come into production in reasonable commercial quantities or to be related to a potential or actual extension thereof. ...

More submissions were received and these were given serious consideration before the final guidelines were issued in June 1994. ...

We have taken into consideration the facts you stated in a letter of June 22, 1994 from XXXXXXXXXX addressed to the Vancouver District Taxation Office. ...

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. ...

(Don Miller, Audit) faxed a sketchy set of facts which can be condensed as follows: Aco gets 40% of Bco shares as consideration for guaranteeing a $15m bank loan. ...

Therefore, I have forwarded your letter to the Honourable Paul Martin, Minister of Finance, for his consideration of your suggestion that the regulation be harmonized with the Ontario Teachers Pension Act. ...

On the amalgamation, NR Corp received 10% of the issued common shares of Publico as consideration for its shares of the capital stock of one of the predecessor corporation. ...

OUR VIEWS As stated in paragraph 3 of Interpretation Bulletin IT-110R2, we consider that a gift, for purposes of subsections 110.1(1) and 118.1(1) of the Act, is a voluntary transfer of property without valuable consideration. ...

David Dodge, Deputy Minister of Finance for his consideration. I wish to thank you for bringing this matter to my attention. ...