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In addition to the facts set out in the above-noted memoranda careful consideration has been given to the information provided to us by 19(1) and 19(1) 24(1) at the February 27, 1990 meeting in our office which was attended by you. ...

Our Interpretation Bulletin IT-419 is enclosed for your consideration in this regard. ...

You have submitted for our consideration the following hypothetical  situation: Hypothetical Situation:-      Limited Partnership A ("Partnership") is a Limited Partnership  which carries on the business (in Canada) of mining, processing and sales of the processed product.-      Partnership is owned as to 60% by a German resident individual, Mr. ...

30 May 1991 External T.I. 9013245 F- Interpretation of the Definition of "Taxable Preferred Share" Unedited CRA Tags 248(1) taxable preferred share 5-901324 Dear Sirs: Re:  Interpretation of the Definition of "Taxable Preferred Share" in Subsection 248(1) of the Income Tax Act (the "Act") This is in reply to your letter dated June 13, 1990, whereby you requested our opinion concerning our interpretation of paragraph (b) of the definition of "taxable preferred share" in subsection 248(1) of the Act, in a situation which you described as follows: 24(1) You requested our opinion as to whether a 24(1) could be considered to be a "taxable preferred share" by virtue of clauses (b)(i)(A) or (C) of the definition of that expression in subsection 248(1), and whether the phrase "it may reasonably be considered having regard to all the circumstances" in that definition provides any latitude in the applicability of the dividend entitlement clauses under consideration. ...

Each shareholder of Opco received a one common share and one special share of Holdco as consideration for each common share of Opco disposed of. 3.      ...

Paragraph 4 of IT-491 sets out some factors that may be taken into consideration when determining the main or chief use of a property.  ...

The level of reserves required by provincial legislation would also be an important consideration. ...

Whether or not a particular legal defeasance is a legal defeasance which effects novation can only be determined following consideration of all of the terms and conditions pertaining to the particular defeasance.  ...

Should you have a factual situation involving an actual taxpayer that you wish to have considered, you should forward all relevant facts and documentation to the appropriate district taxation office for their consideration. ...

Meeting with Finance In response to numerous queries received from Revenue Canada concerning the proposed Part 1.3 tax; Finance agreed to attend a meeting with us to discuss their intent and policy considerations inherent in the drafting of the Part 1.3 legislation. ...