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Autres considérations Toutefois, si le contribuable reçoit l'une des aides gouvernementales décrites précédemment sans en rencontrer les buts et objectifs alors que les dépenses faites, en vue de tirer un revenu, sont de nature courante, l'aide gouvernementale reçue réduit les dépenses déductibles. ...

However, if an election is made pursuant to subsection 85(l), the agreed amount cannot be less than the fair market value of the non-share consideration pursuant to paragraph 85(1)(b). ...

We note that the object under consideration in The Gulf Aladdin case was a tanker barge which was pulled by tug from place to place. ...

Upon the wind-up, the acquiring corporation increases the book value of the assets of the acquired corporation by the difference between the consideration paid for the shares of the acquired corporation and book value of those assets. ...

Although this is considered to be more of a theoretical than a practical question in light of the likelihood of our becoming aware of such infrequent absences, the answer would have to take all of the taxpayer's particular circumstances into consideration. b) A trainman maintains an apartment at an away-from-home location in a prescribed area and his family resides in a non-prescribed area. ...

The comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

While commercial reasons may abound, it is clear that income tax considerations are also prominent in the design of plans. ... As indicated in paragraph 3 of the bulletin, to be a "contract of insurance" or a "medical care insurance plan" a PHSP must contain the following basic elements: (a) an undertaking of one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ... Answer Where a PHSP is self-insured (i.e., the consideration for the "insurance" is regarded as the employees' covenants in their contract of service with the employer), it is the Department's view that the plan should cover all employees (or all employees within a specific category) in one plan with the same coverage for each employee. ...

While commercial reasons may abound, it is clear that income tax considerations are also prominent in the design of plans. ... As indicated in paragraph 3 of the bulletin, to be a "contract of insurance" or a "medical care insurance  plan" a PHSP must contain the following basic elements:           (a) an undertaking of one person,          (b) to indemnify another person,          (c) for an agreed consideration,          (d) from a loss or liability in respect of an event,          (e) the happening of which is uncertain. ... Answer Where a PHSP is self-insured (i.e., the consideration for  the "insurance" is regarded as the employees' covenants in  their contract of service with the employer), it is the  Department's view that the plan should cover all employees (or all employees within a specific category) in one plan  with the same coverage for each employee.  ...

Considerations: a) trader or dealer recognizes all transactions on income account b) adventure in the nature of trade c) intention of taxpayer includes secondary intention d) number of frequency of transactions e) length of holding time f) method of disposition g) nature of the transaction 2. ... [*Note: A novation occurs when an original obligation is discharged by agreement of the parties and a new obligation with new consideration is undertaken, usually, but not necessarily, on the same terms, with a different creditor or debtor. ... Instead, it is viewed as inherent in the determination of any gain or loss on the forward contract, which gain or loss can only be determined at the time of contract fulfillment and is equal to the difference between the payment made under the contract and the Canadian-dollar value of the consideration received therefor, where such consideration is translated to Canadian dollars at the spot rate in effect on the date of delivery. ...

This leads to a consideration of whether, legally speaking each of the holdbacks in the instant case possessed the quality required to bring it within the meaning of a receivable. ...