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The scenario under consideration involves a child (the "Child") and her separated parents ("Individual A" and "Individual B"). ... We would generally expect that each parent obtain a receipt from the caregiver for his or her share of the child care expenses paid by the parent; however, the circumstances under consideration are somewhat different because Individual B is paying the caregiver for child care services provided to the Child in respect of Individual A and herself and is receiving a reimbursement of 60% of the costs from Individual A. ...

The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. ... Question 4 With consideration of the information in Q3, paragraph 8 states that medical and health insurance plans offered by Blue Cross qualify as PHSPs. ...

Your letter also stated that the Regional Municipality whose jurisdiction includes the land under consideration will not allow further subdivisions on that particular acreage. ... As a final consideration, in granting the surface lease, it is likely that the taxpayer has had a partial change in use of the property from personal use to income-producing (see paragraph 30 of IT-120R5). ...

In general, for Canadian tax purposes, an arrangement is a pension plan if contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee or, in some cases, where amounts have been contributed by a government. ... While you have not requested this information, we offer the following comments for your consideration. ...

" (The Net Profits Interest in the Oil and Gas Industry- An In-Depth Analysis), Canadian Petroleum Tax Journal, Vol. 1, 1988: An NPI can arise in essentially two ways: one party conveys away or disposes of a 'Canadian resource property' and takes back the NPI as consideration therefor or, alternately, carves-out the NPI from an interest he continues to hold and conveys it to another, perhaps for geological services or even simply for a cash payment. In either case, once created, an NPI can be transferred to a third party for consideration. ...

In the event that the share consolidation results in a shareholder owning a fraction of a post-consolidation Pubco1 share (for example, assume 1050 pre-consolidation Pubco1 shares will be replaced by 10.5 post-consolidation Pubco1 shares), Pubco1 will pay the shareholder an amount not exceeding $200 as consideration for the shareholder's fractional (0.5) Pubco1 share. ... Since you believe that the 116 clearance certificate requirement would impose a practical burden on Pubco2 non-resident shareholders, we will forward a copy of this letter to the Department of Finance for their consideration. ...

In your letter you described a hypothetical situation for our consideration which has been restated as follows. ... For the purposes of the comments that follow it is assumed that none of these exclusions (i.e., transfers for FMV consideration, loans for value, or spouses living apart) are applicable in this case. ...

One of the tax considerations which may be relevant in considering the choice of trustee for a testamentary trust is the treatment of dividends received by a trust. ... We hope you find this information on possible tax considerations useful in your estate planning. ...

In this regard, we refer you to the comments in paragraph 5 of Interpretation Bulletin IT-239R2, "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-Arm's Length Circumstances," a copy of which is enclosed. ... Rather, it appeared that you had settled your son's debt for no consideration. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...