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In this regard, I have forwarded a copy of our correspondence to the Honourable Paul Martin, Minister of Finance, for his consideration. ...

Accordingly, I have sent a copy of our correspondence to the Honourable Paul Martin, Minister of Finance, for his consideration. ...

Box 8500 David Shugar Ottawa, Ontario K1G 3H9 Attention: Ms Rita Bowry March 29, 2000 Dear Ms Bowry: Re: Awards and Research Grants We are writing in reply to your letter of December 13, 1999 requesting our views on the taxation of the revised Centre Internship Award and the Professional Development Award taking into consideration the modifications made to the awards. ...

In this regard, I note that XXXXXXXXXX office sent a copy of your letter to the Honourable Paul Martin, Minister of Finance, for consideration. ...

You presented a hypothetical scenario for our consideration and queried whether the term "goods and services" would include the rental of real property. ...

Position: No but consideration of the application of subsection 69(11) is required. ...

In this regard, we will give due consideration to this issue if it is received in the form of a request for an advance income tax ruling. ...

In the particular opinion given, the view was expressed that a PHSP must have the basic elements of an insurance plan, namely, an undertaking by one person; to indemnify another person; for an agreed consideration; from a loss or liability in respect of an event; the happening of which is uncertain. ...

Principal Issues: Whether a swap of securities between RRSP/RRIF and non-registered accounts is treated as a purchase and sale Position: Question of fact Reasons: Depends on intention of parties and whether equivalent consideration passes between parties. ...

In the particular opinion given, the view was expressed that a PHSP must have the basic elements of an insurance plan, namely, an undertaking by one person to indemnify another person for an agreed consideration from a loss or liability in respect of an event, the happening of which is uncertain. ...