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The shares issued must represent full consideration for the patronage dividend required. ...

We offer the following general comments concerning benefits from or under a trust to a life tenant for your consideration. ...

Gary Donell, communicated your concerns and forwarded a copy of your correspondence, to our Technical Publications Directorate for their consideration. ...

A taxpayer who has shares issued to his spouse or children by a corporation, as described in Kieboom, will be considered to have disposed of property and will be deemed to have received a consideration equal to the fair market value of the property under subparagraph 69(1)(b)(i). ...

When a requested interpretation relates to a completed transaction, it should be referred to the taxpayer's local tax services office for their consideration. ...

In any event, it would be a question of fact as to exactly what services would be performed or what information would be provided by Usco and HK Co. in consideration for the fees paid to Usco and HK Co. ...

In view of your comments concerning the desire of mutual fund investors to obtain more information on tax issues raised by mutual fund managers, we will give serious consideration to the publication of additional ATRs that will address some of these issues. ...

We have forwarded all information from the Institute to our International Tax Programs Directorate for possible future consideration. ...

The Income Tax Act contains numerous provisions pertaining to the organization and operation of not-for-profit and charitable organizations and, as a result, like commercial enterprises, advance rulings may also be required to provide assurance with respect to the income tax implications of transactions under consideration. ...

We will, however, bring this matter to the attention of the Department of Finance for their consideration. ...