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Accordingly, given your concern that an annuity received as a consequence of an individual's participation in a foreign pension scheme may be inappropriately taxed, you may wish to refer this matter to the Department of Finance for their consideration in the finalization of the proposed legislation. ...

This factor was a major consideration in agreeing to the Settlement. 10. ...

In consideration of the Insurers making such payments, the Claimant settles XXXXXXXXXX claims against the Defendants. ...

Paragraph 260(8)(b) provides that where the borrower of securities has provided the lender with money, either as collateral or as consideration for the securities, and the borrower does not pay or credit a reasonable amount to the lender as a fee for the use of the securities, an amount calculated under that paragraph is deemed to be an amount paid under the arrangement by the borrower to the lender as a fee for the use of the securities. ...

(ii) the development of real estate for sale, the lending of money, the leasing or licensing of property or the insurance or reinsurance of risks, and (b) the affiliate...employs (i) more than 5 employees full time in the active conduct of the business, or (ii) the equivalent of more than 5 employees full time in the active conduct of the business taking into consideration only the services provided by its employees of (A) a corporation related to the affiliate (otherwise than because of a right referred to in paragraph 251(5)(b)),... where the corporation...referred to in clause (A) receive compensation from the affiliate...for the services provided to the affiliate...by those employees the value of which is not less than the cost to such corporation...of the compensation paid or accruing to the benefit of those employees that perform the services during the time the services were performed by those employees. ...

While the residence status of an individual can only be determined on a case by case basis after taking into consideration all of the relevant facts (please refer to Interpretation Bulletin IT-221R3, "Determination of an Individual's Residence Status" which is available on our website at www.ccra-adrc.gc.ca for a detailed discussion of such facts), it appears that an employee who commutes to work in New York state but returns to his or her home in Canada each night after work would most likely be considered factually resident in Canada. 2. ...

., a U.S. public corporation, agreed to advance up to $5 million to Alias in consideration of a security interest in Alias' assets and the issuance of warrants to acquire common shares of Alias. ...

Toutefois, l'ADRC est disposé à prendre en considération tous les autres facteurs pertinents, incluant la valeur économique de la superficie occupée aux fins de l'exploitation d'une entreprise selon les circonstances particulières d'une situation donnée. ...

Les parties ont convenu que la somme de XXXXXXXXXX $ par mois proviendrait des revenus nets de location d'un immeuble transféré entièrement à Madame en considération de la dissolution du mariage. ...

Generally speaking and as discussed in Interpretation Bulletin IT-405, Inadequate Considerations- Acquisitions and Dispositions, the rules address transactions that do not occur at fair market value and ensure, amongst other things, that the transferor of property does not artificially reduce the proceeds of disposition and the transferee does not inflate the cost of acquisition. ...