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However, as this position requires a factual determination in each case, consideration should be given to changing lines 12 and 13 of paragraph 1(f) of IT359R3 [IT-359R3] to read something like the following: “However, the Department will not ordinarily consider changes to an agreement to be minor in respect of the following:” (3) We agree that there is no apparent tax relief to the recipient of an inducement in those situations where the inducement is repaid, and this repayment occurs after the disposition of a property that was subject to a subsection 53(2.1) cost reduction. (4) Our position regarding the treatment by lessors of lease inducement payments is under review. ...

As a final comment, we are mentioning that in the above case, there may be other considerations (e.g., it appears that there is an employment contract in addition to the Agreement). ...

(b) Departmental guidelines under which consideration is given to recommending a remission of tax to Treasury Board are substantially as outlined in the Canadian Tax Journal (1986, Vol. 34, No. 4, pp. 801-827), The Department could not generally support a remission of tax under the Financial Administration Act for employees incurring home office expenses that are not specifically deductible from employment income under the Income Tax Act. ...

We, however, do provide the following comments for your consideration: 1. ...

Fortunately, there is probably very little practical difference, if any, so that consideration of a change could be left to next year. 6. ...

Other Issue XXX It may be reasonable to consider a portion of the lump sum payment to have been in respect of such services and not as consideration for the use of the software. ...

The comments set out in this letter are of a general nature and do not take into account the numerous additional considerations that might arise in the context of specific factual situations. ...

Subsequent to the acquisition of the common shares of Opco by Purchaser Company, the shareholders of Purchaser Company will transfer all of their shares of Purchaser Company to Opco and, as sole consideration for the transfer, will receive shares of Opco. ...

Thus, the issuance to each of the brothers of high PUC shares of his Holdco in consideration of the transfer of his Investco shares would not, in our opinion, result directly or indirectly in a misuse of section 84.1 of the Act or an abuse having regard to the provisions of the Act read as a whole. ...

., but a corporation shall be deemed not to have acquired control of a corporation if it has not purchased (or otherwise acquired for a consideration) any of the shares in the capital stock of that corporation. b) There shall be included in computing a corporation's income all gifts received by the corporation and all amounts contributed to the corporation to be used for scientific research and experimental development. ...