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FACTS Our understanding of the relevant facts is as follows: Subsection (2) of the Notice of Ways and Means tabled in the House of Commons on September 18, 2001 states: "(2) Subsection (1) applies in respect of expenditures made by a taxpayer on or after September 18, 2001 in respect of a right to receive production, (in this subsection referred to as the "right"), except if (a) the expenditure is (i) required to be made under a written agreement made by the taxpayer before September 18, 2001, (ii) made under, or described in, the terms of a prospectus, preliminary prospectus or registration statement that is, before September 18, 2001, filed with a public authority in Canada in accordance with the securities legislation of Canada or of a province and, if required by law, accepted for filing by the public authority before September 18, 2001, or (iii) made under, or described in, the terms of an offering memorandum distributed as part of an offering of securities if (A) the memorandum contains a complete, or substantially complete, description of the securities contemplated in the offering as well as the terms and conditions of the offering, (B) the memorandum was distributed before September 18, 2001, (C) solicitations in respect of a sale of the securities contemplated in the offering have been made before September 18, 2001, and (D) the sale of the securites contemplated in the offering is substantially in accordance with the memorandum; (b) the expenditure is made before 2002; (c) the expenditure is paid in consideration for services that are rendered in Canada before 2002 in respect of an activity, or a business, all or substantially all of which is carried on in Canada; (d) there is no agreement, or other arrangement, under which the obligation of any taxpayer in respect of the expenditure can be changed, reduced or waived if there is a change to, or an adverse assessment under, the Act; (e) if the right is, or is related to, a tax shelter investment, a tax shelter identification number in respect of the tax shelter was obtained before September 18, 2001; and (f) if the expenditure is made under, or described in, the terms of a document that is a prospectus, a preliminary prospectus, a registration statement or an offering memorandum (and regardless of whether the expenditure is also made under a written agreement) (i) all of the funds raised pursuant to the document that may reasonably be used to make a matchable expenditure are raised before 2002, (ii) all or substantially all of the securities distributed pursuant to the document for the purpose of raising the funds described in subparagraph (i) are acquired before 2002 by a person who is not (A) a promoter, or an agent of a promoter, of the securities, (B) a vendor of the right, (C) a broker or dealer in securities, or (D) a person who does not deal at arm's length with a person referred to in clause (A) or (B), and (iii) all or substantially all of the funds raised pursuant to the document before 2002 are used to make expenditures that are required to be made pursuant to agreements in writing made before September 18, 2001. ...

Les facteurs pertinents qui doivent être pris en considération diffèrent selon la nature et la portée de l'activité ou du travail. ...

As consideration for the assumption by Parent of the obligation to provide post-retirement benefits, Subsidiary will establish the RCA Trust. ...

On or about XXXXXXXXXX, DC2 disposed of some of its Pubco2 shares at fair market value for cash consideration only and realized a capital gain. ...

These guidelines take into consideration a number of factors to determine the amount a parent may claim as child support. ...

Paragraph 118.2(2)(q) of the Act provides that a premium, contribution or other consideration under a PHSP is a medical expense of an individual for the purposes of subsection 118.2(1) of the Act if they are paid in respect of the persons listed in paragraph 118.2(2)(q), except to the extent that a deduction under subsection 20.01(1) of the Act is available. ...

The Board will terminate the Plan on the XXXXXXXXXX with the consent of the Participants and in consideration of such termination each Participant will be granted the right to be paid a cash settlement amount (the "Settlement Amount") on any business day between XXXXXXXXXX and XXXXXXXXXX (the "Settlement Date"). ...

In consideration for providing a turn-key operation for a restaurant by providing leased premises, training, equipment and supplies, the franchisee pays an up-front franchise fee as well as ongoing contributions towards the operation of the franchise (such as contributions to an advertising fund) and also pays a monthly royalty payment based on its gross sales. ...

Since the Act does not specify the point at which such entitlement arises, it must be determined based upon a review of the relevant facts of each particular situation, taking into consideration the ordinary meaning of the word 'entitled.' In order for a taxpayer to be 'entitled to receive' an amount, the taxpayer must have a clear legal right to receive the amount, and all of the pre-conditions to a 'right to receive' the amount must have been satisfied. ...

Holdco1 will subscribe for XXXXXXXXXX common shares of Subco, which will constitute all the outstanding shares of Subco, in consideration for which it will pay a nominal amount to Subco. 19. ...