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Taking into consideration the input of stakeholders, the CRA further pursued its analysis of the legislative and system requirements needed to implement the RTPP. ...

The insured policyholder could be required to pay increased premiums due to increased age or ratings due to health considerations or the life insured is no longer insurable. ...

Position: The AG has recommended that a statement of assets and liabilities (a balance sheet) be required to be filed with the T3 return; her recommendation is under consideration Reasons: See 2005 AG report, chapter 3 in particular for full details of the AG's recommendations with respect to the assessment and auditing of trusts. 2006 STEP Round Table Q1. ...

The income derived by FA2 from payments received from FA1 in consideration for reinsuring the contracts of FA1, is deemed to be income from an active business pursuant to subparagraph 95(2)(a)(ii). ...

Cette considération importante n'apparaît pas comme étant bien comprise par plusieurs parents à revenu plus modeste ayant la garde d'enfants. ...

DEPARTMENT'S POSITION Whether all, or any portion of, such fees or payments are subject to withholding tax is a question of fact which can only be determined with full knowledge of all of the facts concerning a particular situation and after consideration is given to the provisions under paragraph 212(1)(d) of the Act, Regulation 105 and the Canada-U.S. ...

A taxpayer who has shares issued to his spouse or children by a corporation, as described in Kieboom, will be considered to have disposed of property and will be deemed to have received a consideration equal to the fair market value of the property under subparagraph 69(1)(b)(i). ...

Concerns regarding the potential application of subsection 15(1) of the Act in other situations involving corporate-owned life insurance policies should be submitted to this Directorate for consideration by way of an advance income tax ruling request in the case of proposed transactions or to the local tax services office in the case of completed transactions. ...

For example, if the trust was an inter vivos trust, it will not qualify as a "personal trust" as defined in subsection 248(1) if the beneficiary's interest in the trust was acquired for consideration payable directly or indirectly to the trust or to any person who has made a contribution to the trust. ...

A transfers his shares of the capital stock of Opco 1 to Opco 2 in consideration for a note. ...