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Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office. ... I can assure you that you will receive the utmost consideration possible in the resolution of your case. ...

TAX STUDY GROUPS ROUND TABLE Q. 26: Paid-up capital of shares owned by non-resident Section 84.1 permits a transferor to receive, without triggering a deemed dividend, non-share consideration having a value equal to the greater of the adjusted cost base and the paid-up capital of the shares being transferred. However, the maximum value of the non-share consideration that a non-resident transferor can receive, without triggering a deemed dividend under section 212.1, is equal to the paid-up capital of the transferred shares. ...

19 December 1989 Income Tax Severed Letter 5-8642A Unedited CRA Tags 85(1) Attached for your review are: 1. a copy of an enquiry letter from XXX dated August 24, 1989; 2. a copy of the opinion letter letter to XXX referred to in the the XXX 3. a draft response to the XXX enquiry in which we take the position that: (a) the tax position of the vendor is irrelevant in determining the fair market value of the property for the purposes of subsection 85(1) of the Act; and (b) the deferred tax liability of the vendor cannot be "assumed"' by the purchaser as a part of the consideration for the transferred property. ... May we have your comments on the position we propose to take with respect to the impact of a deferred tax liability of the vendor on the determination of the fair market value of a property for the purposes of subsection 85(1) of the Act in the situation under consideration? ...

19 December 1989 Income Tax Severed Letter 5-8642C Unedited CRA Tags 85(1) Attached for your review are: 1. a copy of an enquiry letter from XXX dated August 24, 1989; 2. a copy of the opinion letter letter to XXX referred to in the the XXX 3. a draft response to the XXX enquiry in which we take the position that: (a) the tax position of the vendor is irrelevant in determining the fair market value of the property for the purposes of subsection 85(1) of the Act; and (b) the deferred tax liability of the vendor cannot be "assumed"' by the purchaser as a part of the consideration for the transferred property. ... May we have your comments on the position we propose to take with respect to the impact of a deferred tax liability of the vendor on the determination of the fair market value of a property for the purposes of subsection 85(1) of the Act in the situation under consideration? ...

Fioravanti (613) 995-1787 April 19, 1984 Dear Sirs: This will reply to your letter of April 3, 1984 requesting that consideration be given to an accelerated rate of depreciation for tax purposes for the advanced Argon Laser System due to the rapid technological obsolescence inherent in this type of equipment. ... Since your request would require an amendment to the Income Tax Regulations we have referred a copy of your letter to our Regulations Division for their consideration. ...

In closing you requested our consideration of these issues with the view to possibly amending the current RCA rules in the Act. ... Wilson, Minister of Finance, we will arrange to have your letter forwarded to his office for consideration. ...

Allington- 957-2064 A/Chief, Research and Enquiries Section Stock Option Plans Further to our recent telephone conversations this will confirm that the Department of Finance, following a meeting with the Tax Executives Institute, have asked that consideration be given to providing guidelines in the booklet, "Income Tax Deductions at Source- Tables",so that employers are aware of the possibility of reduced withholding requirements where paragraph 110(1)(d) would have application. It is understood that you will give this matter consideration, and for your information we are enclosing a copy of the issue paper received from Finance. ...

Tax Study Groups Round Table Q. 26: Paid-up capital of shares owned by non-resident Section 84.1 permits a transferor to receive, without triggering a deemed dividend, non-share consideration having a value equal to the greater of the adjusted cost base and the paid-up capital of the shares being transferred. However, the maximum value of the non-share consideration that a non-resident transferor can receive, without triggering a deemed dividend under section 212.1, is equal to the paid up capital of the transferred shares. ...

Following our letter to you dated October 30, 1986, this matter was referred to the Publications Division for their consideration in the context of a revision or addition to IT-341R. We have been advised that while the above will be given consideration there is no immediate plan by the Publications Division to revise IT-341R. ...

Paragraph 110.6(14)(f) provides that shares issued after June 13, 1988 by a corporation to a taxpayer shall be deemed to be owned immediately before their issue by a person who was not related to the taxpayer unless the shares were issued as consideration for other shares or as part of a transaction or series of transactions involving  certain dispositions of property to the corporation. ... Will Revenue Canada comment on whether the "new" shares should be regarded as having been issued as consideration for the "old" shares and, as a result, will not be considered to have been owned by a person not related to the individual taxpayer? DEPARTMENT'S POSITION It is our view that, if shares are considered as a matter of the relevant corporate law to be issued when shares are "changed" in the manner described above, the "new" shares are issued as consideration for other shares for purposes of subparagraph 110.6(14)(f)(i) of the Act.  ...