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As discussed with you during our telephone conversation on June 26, 1989, any specific queries you may have concerning 24(1) Appeals Branch for their consideration. ...

In addition to the facts described in their letter, we have been told to assume that there was only one class of shares, there were no V-Day value considerations involved, and the transaction was not tax motivated. ...

Conveyance of interest in property for specified period usually in consideration of rent,      a "lessee" as one who rents property from another. ... One who has use and occupation of real property of a landlord... the terms of this tenancy being fixed by a "lease", and      "rent" as consideration paid for use or occupation of any property, land, buildings, equipment, etc.            ... On the basis of the above dictionary definitions a lease arrangement for the purposes of the definition of "approved project property", could be considered, in our view, to include an arrangement between a landlord and a tenant which results in the use of real property for a specified period of time for consideration that is rent. 3.      ...

We have reviewed the submissions made in respect of the cases submitted for your consideration and are of the opinion that subsection 8504(7) of the regulations will apply to exclude the application of subsection 8504(6). ...

In our view the election described above is for purposes of the GST only would not in and by itself adversely affect the status of an organization for purposes of paragraph 149(1)(1) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...

In view of the foregoing, we request that you give further consideration to processing the taxpayer's 1986, 1987 and 1988 returns on the administrative basis described in this memorandum and its related Schedules "A" and "B". ...

This position was apparently based on two considerations: 23 21(1)(b) As a result of 1985 amendments to section 84.1 which have removed the policy concerns referred to above, and the 1988 Tax Court of Canada decision in Estate of Karna Mav v. ...

Otherwise it would not be appropriate to refer to that IT in paragraph 6 of the Project. 21(1)(b) We have also suggested other minor editing changes to the Project for your consideration as noted thereon.  ...

After careful consideration of the matters raised, 24(1) When the remission guidelines are not met, the remission process cannot provide relief from taxation beyond that already made available by parliament to all taxpayers under the Income Tax Act. ...

However this is a question of fact, that can only be determined after consideration of the circumstances of a particular situation. ...