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This deeming provision enables the payer to obtain a deduction under paragraph 60(b) of the Act, provided the payments otherwise qualify, and ensures that third party payments are taken into consideration in determining the amount the payer may deduct under paragraph 60(b) of the Act. ...

c) If the rules do apply to foreign property to cause deemed dispositions of such property and related foreign accrual property income (FAPI), would the adjusted cost base of such property to the trust be the original cost of the property to the trust adjusted for valuation day considerations or the gain as may reasonable be considered to have accrued after its 1975 taxation year in accordance with the definition of "foreign accrual property income"? ...

These comments are general in nature and do not specifically take into consideration the facts in the hypothetical situation which you outlined. ...

The only consideration given by Amalco to the Creditor for the settlement of the Relevant Debt was the New Debt. ...

Pursuant to paragraphs 18(1)(a) and 18(1)(e), no deduction or reserve would be allowed in the year of receipt to take into consideration obligations that the recipient would have to perform or fulfill in the following years. 2) Amounts received pertain or are incident to the active business carried on by the taxpayer. ...

However, the situation described in the Second Document requires a different analysis depending on which portion of the land is under consideration. ...

Avant d'aborder la question du coût au regard de l'article 69 de la Loi, encore faut-il prendre en considération les conséquences spécifiques de la création d'un usufruit dans le cadre de la Loi. ...

Therefore, since no consideration would be given by Miss M in return for the Securities and since the acquisition of these properties by Miss M would fall outside the ambit of paragraph 69(1)(c) of the Act, the cost of the Securities to Miss M following their transfer to her would be nil. ...

20 December 2004 External T.I. 2004-0092871E5 F- Arm's Length: de facto control Unedited CRA Tags 251(1)(c) 256(5.1) 84.1 Principal Issues: Whether, in a given fact situation, subsection 84.1(1) would apply to deem a dividend to have been received by an individual who received a term note in consideration of shares of the capital stock of a "subject corporation" transferred to a "purchaser corporation"? ...

Accordingly, should you require any assistance with respect to any particular plan, you should provide the details of the plan to the appropriate tax services office for their consideration. ...