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Position: Confirmed that under the present law, the payment would not qualify and referred issue to Department of Finance for their consideration. ... Flaherty, Minister of Finance, for his consideration. Thank you again for having taken the time to write. ...

We concur that, in Situation 1, the acquisition of a beneficial interest in the trust by the Contributor at the time of settlement would not disqualify the trust as a personal trust, because there was no consideration given by the Contributor for this interest in the trust.  ... We also concur that, in Situation 2, the acquisition of a beneficial interest in the trust by the settlor at the time of settlement would not disqualify the trust as a personal trust, because the definition of a personal trust includes a provision which deems the settlor to have acquired his beneficial interest for no consideration.  ...

10 September 2009 Ministerial Correspondence 2009-0333181M4- First-time home buyers' plan Principal Issues: Would an individual qualify for the first-time home buyers' tax credit (HBTC) if the only consideration paid by the individual for the home is the assumption of an existing mortgage from the previous home owner? ... 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. ...

Under this procedure, the Tax Court is not bound by legal or technical rules of evidence and is required to deal with appeals as expeditiously as the circumstances and considerations of fairness permit. ... Should your constituent's client submit a Form T2201 containing all the information required to his local Tax Services Office, due consideration will be given to whether he or she is entitled to the disability tax credit. ...

Adler   (613) 957-8962 February 22, 1990 Dear Sirs: This is in reply to your letter dated January 12, 1990 in which you requested clarification of this Department's interpretation of "any group of employees" as used in paragraph (d) of the definition of "designated shareholder in subsection 4901(2) of the Income Tax Regulations ("Regulations"), and provided the following two examples for our consideration.       ... Wilson, Minister of Finance, we suggest that you pursue your concerns on this issue by writing to relevant officials in his Department for their consideration. ...

Cockell   957-9226 SUBJECT: PROPOSED CONFERENCE ATTENDANCE 1990-1991 Consideration could be given to sending one person from this Division (Director or Chief) to the Canadian Tax Foundation Annual Conference. ...

The determination in a particular situation would be based on consideration of all the relevant facts and supporting documents. This may include consideration of an opinion of a qualified medical practitioner describing the nature and purpose of the procedure in enough detail to be able to make a determination. ...

If the funding taxpayer receives, in consideration for a reasonable royalty payable to such a researcher, the exclusive rights to manufacture and distribute in Canada products made as a result of using those rights, the funding taxpayer would normally be considered to be entitled to exploit the results of the SR&ED performed.  This entitlement will not be affected in the situation where that funding taxpayer also had the rights to manufacture and distribute products outside Canada and assigned those rights to another corporation in consideration for royalties to be received based on the use of those rights. ...

The relatives subscribe for common shares of Newco for nominal consideration.  ... As sole consideration, Newco issues its preference shares to Famco having a redemption amount equal to the fair market value of the assets transferred to Newco and a aggregate paid-up capital equal to the aggregate cost amount of the assets transferred.  ...

Flaherty, Minister of Finance, for his consideration. I trust the information I have provided and the referral are helpful. ...