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3 December 1990 Ministerial Correspondence 903344 F- Shares Issued as Consideration for All or Substantially All of the Assets Used in an Active Business Unedited CRA Tags 54.2, 96 24(1) 903344   C. ... You question whether the word "person" includes a partnership, for the purposes of section 54.2 of the Act, where a partnership has disposed of property that consisted of all or substantially all of the assets used in an active business carried on by that partnership to a corporation for consideration that includes shares of the corporation. ...

Accordingly, does section 84 apply where non-share consideration is received by a shareholder of the amalgamated corporation as part of the exchange of his shares of the predecessor corporation for the new shares of the amalgamated corporation? ... As a result, an amalgamation can be an amalgamation to which section 87 applies even where a shareholder of a predecessor corporation receives both shares of the amalgamated corporation and non-share consideration in exchange for shares of the predecessor corporation.  On this basis, the position in paragraph 52 of IT-474R would apply to a section 87 amalgamation where the shareholder of a predecessor corporation receives both shares in the amalgamated corporation and non-share consideration in exchange for shares in the predecessor corporation. ...

Reasons: The fact that the only consideration paid by the individual for a home is the assumption of an existing mortgage does not in itself preclude the individual from qualifying for the HBTC if all the conditions for the credit are met. ... You want to know if you and your spouse will be eligible for the HBTC if you acquire a home that is subject to a mortgage and the only consideration given is the assumption of the mortgage from the previous owner. ... The fact that the only consideration paid for a home is the assumption of an existing mortgage does not in itself prevent you and your spouse from qualifying for the HBTC. ...

The agreements between the parties reflecting this arrangement would be examined in order to determine whether, in fact, there is no consideration received from A Co for the use of these vehicles.  Even though there may be no cash payment from A Co, there may be equivalent consideration in the form of advertising or promotional service provided by A Co in exchange for the use of the demonstrator cars.  ... On the assumption that the value of the consideration for the use of the cars supplied by the manufacturer is the annual cost of leasing a similar vehicles by A Co, that value would be considered as "amounts that may be reasonably regarded as having been payable by the employer to a lessor... ...

There were no agreements, nor were any contemplated between the guarantor and the corporation respecting any consideration in exchange for the guarantee. ... The Department's position as stated in paragraph 3 of IT-239R2 is that a capital loss arising from honouring a guarantee given for inadequate or for no consideration is nil by virtue of subparagraph 40(2)(g)(ii) of the Act. ... The subsequent carrying charges respecting borrowed funds to discharge the loan would also not be deductible as the guarantor did not receive any consideration for the guarantee and therefore the expenditures would not be considered to be for the purpose of producing income. ...

I am also sending your comments about the clarity of the CRA's publications and frontline services to the responsible CRA officials for their review and consideration. ... Flaherty, Minister of Finance, for his consideration. I trust that the referrals are helpful. ...

., voluntary transfers of real or personal property without consideration) are not subject to tax in the hands of the recipients. ... However, the Canada Revenue Agency's general position is that recipients do not have to pay tax on most gifts and inheritances, also known as voluntary transfers of real or personal property without consideration. ...

To assist taxpayers, the CRA provides relief in extraordinary circumstances, such as after a natural disaster, by giving special consideration to taxpayers who have trouble meeting their tax obligations. ... Therefore, I am sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...

Position: Confirmed that under the present law, the payment would not qualify and referred issue to Department of Finance for their consideration. ... I am therefore forwarding a copy of your letter to the Honourable Jim Flaherty, Minister of Finance, for his consideration. ...

Accordingly, the taxpayer's suggestion was referred to the Honourable James Flaherty, Minister of Finance for his consideration. ... Flaherty, Minister of Finance, for his consideration. I trust that the referral is helpful. ...