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Paragraph 4 of the bulletin is revised for clarification and to take into consideration the amendment to the preamble of subsection 107(2) enacted under S.C. 1988, c.55 (formerly Bill C-139) applicable to distributions after 1987. ... Paragraph 5 of the bulletin is revised to take into consideration the amendment to the definition of "cost amount" in subsection 248(1) enacted under S.C. 1994, c.7 (formerly Bill C-15) applicable after May 22, 1985. ...

However, where such a debt was of a kind that would have qualified for consideration as a bad debt had it been retained until the end of the taxation year, any loss at the time of its disposition, or later because of non-payment by the debtor, would normally be deductible by the taxpayer as a general business expense. ... A taxpayer who is in the money-lending business, as in the case of any other taxpayer, may make loans that are not prompted by the ordinary considerations that govern the making of loans in a money-lending business. 13. ... Although the length of time that an account is in arrears is generally an important consideration in deciding whether the account is doubtful of collection, in certain circumstances a lengthy delay may occur without the account being so considered. ...

It is the Department's view that a transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital for the purposes of paragraph 53(1)(c). ... In computing the ACB of a capital interest of a taxpayer in a trust, other than an interest in a "personal trust" (see 16 below) acquired by the taxpayer for no consideration or an interest of the taxpayer in those trusts referred to in 15 below, the taxpayer shall (a) deduct under subparagraph 53(2)(h)(i) any amount paid to the taxpayer by the trust after 1971 and before the time of the computation as a distribution or payment of capital by the trust, other than as proceeds of disposition of the interest or part thereof, to the extent that such amount became payable before 1988, (b) deduct under subparagraph 53(2)(h)(i.1) any amount that has become payable to the taxpayer after 1987 (subject to the transitional rules discussed in 14 below) and before the time of the computation in respect of that interest, other than as proceeds of disposition of all or part of an interest, except to the extent of the portion (i) that has been included in the taxpayer's income by reason of subsection 104(13) or, where the taxpayer is not resident in Canada, that is subject to Part XIII tax by reason of paragraph 212(1)(c), or (ii) that, where the trust was resident in Canada throughout its taxation year in which the amount became payable, (A) is equal to one-third (one-half if payable before 1990) of the net taxable capital gains of the trust designated by the trust under subsection 104(21) in respect of the taxpayer, or (B) represents non-taxable dividends of the trust designated by the trust under subsection 104(20) in respect of the taxpayer, (c) deduct under subparagraph 53(2)(h)(ii) any amount deducted for post 1981 taxation years by the taxpayer under subsection 127(5) in calculating the tax otherwise payable under Part 1 for taxation years ending before the time of the computation in respect of an investment tax credit allocated by the trust pursuant to subsection 127(7), (d) deduct under subparagraph 53(2)(h)(iii) the amount of share-purchase tax credit allocated to the taxpayer after the 1982 taxation year by the trust and added under subsection 127.2(3) in calculating the tax otherwise payable under Part 1 for a taxation year ending before or after the time of the computation, (e) deduct under subparagraph 53(2)(h)(iv) 50% of the amount of any scientific research tax credit allocated to the taxpayer after the 1982 taxation year and before the time of the computation by the trust under subsection 127.3(3), and (f) deduct under subparagraph 53(2)(h)(v) the amount of any assistance received by the taxpayer before the time of the computation from a government, municipality or other public authority that has resulted in a reduction to the trust under subsection 13(7.2) of the capital cost of a depreciable property acquired after May 9, 1985. ... A "personal trust" is defined in subsection 248(1) to mean (a) a testamentary trust, or (b) an inter vivos trust, no beneficial interest in which was acquired for consideration payable directly or indirectly to (i) the trust, or (ii) any person who has made a contribution to the trust by way of transfer, assignment or other disposition of property, and, for the purposes of (b) above and paragraph 53(2)(h), where an inter vivos trust is created by way of the transfer, assignment or other disposition of property by an individual (or two or more individuals each of whom was, at the time the trust was created, related to each of the other individuals), any beneficial interest in the trust acquired by such individual (or such individuals) at the time the trust was created shall be deemed to have been acquired for no consideration. ...

However, where such a debt was of a kind that would have qualified for consideration as a bad debt had it been retained until the end of the taxation year, any loss at the time of its disposition, or later because of non-payment by the debtor, would normally be deductible by the taxpayer as a general business expense. ... A taxpayer who is in the money-lending business, as in the case of any other taxpayer, may make loans that are not prompted by the ordinary considerations that govern the making of loans in a money-lending business. 13. ... Although the length of time that an account is in arrears is generally an important consideration in deciding whether the account is doubtful of collection, in certain circumstances a lengthy delay may occur without the account being so considered. ...

It is the Department's view that a transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital for the purposes of paragraph 53(1)(c). ... In computing the ACB of a capital interest of a taxpayer in a trust, other than an interest in a "personal trust" (see 16 below) acquired by the taxpayer for no consideration or an interest of the taxpayer in those trusts referred to in 15 below, the taxpayer shall (a) deduct under subparagraph 53(2)(h)(i) any amount paid to the taxpayer by the trust after 1971 and before the time of the computation as a distribution or payment of capital by the trust, other than as proceeds of disposition of the interest or part thereof, to the extent that such amount became payable before 1988, (b) deduct under subparagraph 53(2)(h)(i.1) any amount that has become payable to the taxpayer after 1987 (subject to the transitional rules discussed in 14 below) and before the time of the computation in respect of that interest, other than as proceeds of disposition of all or part of an interest, except to the extent of the portion (i) that has been included in the taxpayer's income by reason of subsection 104(13) or, where the taxpayer is not resident in Canada, that is subject to Part XIII tax by reason of paragraph 212(1)(c), or (ii) that, where the trust was resident in Canada throughout its taxation year in which the amount became payable, (A) is equal to one-third (one-half if payable before 1990) of the net taxable capital gains of the trust designated by the trust under subsection 104(21) in respect of the taxpayer, or (B) represents non-taxable dividends of the trust designated by the trust under subsection 104(20) in respect of the taxpayer, (c) deduct under subparagraph 53(2)(h)(ii) any amount deducted for post 1981 taxation years by the taxpayer under subsection 127(5) in calculating the tax otherwise payable under Part 1 for taxation years ending before the time of the computation in respect of an investment tax credit allocated by the trust pursuant to subsection 127(7), (d) deduct under subparagraph 53(2)(h)(iii) the amount of share-purchase tax credit allocated to the taxpayer after the 1982 taxation year by the trust and added under subsection 127.2(3) in calculating the tax otherwise payable under Part 1 for a taxation year ending before or after the time of the computation, (e) deduct under subparagraph 53(2)(h)(iv) 50% of the amount of any scientific research tax credit allocated to the taxpayer after the 1982 taxation year and before the time of the computation by the trust under subsection 127.3(3), and (f) deduct under subparagraph 53(2)(h)(v) the amount of any assistance received by the taxpayer before the time of the computation from a government, municipality or other public authority that has resulted in a reduction to the trust under subsection 13(7.2) of the capital cost of a depreciable property acquired after May 9, 1985. ... A "personal trust" is defined in subsection 248(1) to mean (a) a testamentary trust, or (b) an inter vivos trust, no beneficial interest in which was acquired for consideration payable directly or indirectly to (i) the trust, or (ii) any person who has made a contribution to the trust by way of transfer, assignment or other disposition of property, and, for the purposes of (b) above and paragraph 53(2)(h), where an inter vivos trust is created by way of the transfer, assignment or other disposition of property by an individual (or two or more individuals each of whom was, at the time the trust was created, related to each of the other individuals), any beneficial interest in the trust acquired by such individual (or such individuals) at the time the trust was created shall be deemed to have been acquired for no consideration. ...

One of the technical amendments proposes to add new section 177.1 to the Excise Tax Act, which if enacted, would provide that a collective society or a collecting body must, for the purpose of determining tax payable in respect of the supply of a service of collecting or distributing the levy on blank media under the Copyright Act, use a formula to calculate the value of the consideration for their supply of that service to an eligible author, eligible maker, or eligible performer or for their supply of that service to another collective society. Specifically, the formula would deem the value of the consideration to be equal to the value of the consideration for the supply, as otherwise determined for GST/HST purposes, minus part of the value of the consideration that is exclusively attributable to the collection and distribution of the levy on blank media. ...

It is the Department's view that a transaction that otherwise increases the capital of a corporation without any consideration being given by the corporation in respect of that increase may result in a contribution of capital for the purposes of paragraph 53(1)(c). ... In computing the ACB of a capital interest of a taxpayer in a trust, other than an interest in a "personal trust" (see 16 below) acquired by the taxpayer for no consideration or an interest of the taxpayer in those trusts referred to in 15 below, the taxpayer shall (a) deduct under subparagraph 53(2)(h)(i) any amount paid to the taxpayer by the trust after 1971 and before the time of the computation as a distribution or payment of capital by the trust, other than as proceeds of disposition of the interest or part thereof, to the extent that such amount became payable before 1988, (b) deduct under subparagraph 53(2)(h)(i.1) any amount that has become payable to the taxpayer after 1987 (subject to the transitional rules discussed in 14 below) and before the time of the computation in respect of that interest, other than as proceeds of disposition of all or part of an interest, except to the extent of the portion (i) that has been included in the taxpayer's income by reason of subsection 104(13) or, where the taxpayer is not resident in Canada, that is subject to Part XIII tax by reason of paragraph 212(1)(c), or (ii) that, where the trust was resident in Canada throughout its taxation year in which the amount became payable, (A) is equal to one-third (one-half if payable before 1990) of the net taxable capital gains of the trust designated by the trust under subsection 104(21) in respect of the taxpayer, or (B) represents non-taxable dividends of the trust designated by the trust under subsection 104(20) in respect of the taxpayer, (c) deduct under subparagraph 53(2)(h)(ii) any amount deducted for post 1981 taxation years by the taxpayer under subsection 127(5) in calculating the tax otherwise payable under Part 1 for taxation years ending before the time of the computation in respect of an investment tax credit allocated by the trust pursuant to subsection 127(7), (d) deduct under subparagraph 53(2)(h)(iii) the amount of share-purchase tax credit allocated to the taxpayer after the 1982 taxation year by the trust and added under subsection 127.2(3) in calculating the tax otherwise payable under Part 1 for a taxation year ending before or after the time of the computation, (e) deduct under subparagraph 53(2)(h)(iv) 50% of the amount of any scientific research tax credit allocated to the taxpayer after the 1982 taxation year and before the time of the computation by the trust under subsection 127.3(3), and (f) deduct under subparagraph 53(2)(h)(v) the amount of any assistance received by the taxpayer before the time of the computation from a government, municipality or other public authority that has resulted in a reduction to the trust under subsection 13(7.2) of the capital cost of a depreciable property acquired after May 9, 1985. ... A "personal trust" is defined in subsection 248(1) to mean (a) a testamentary trust, or (b) an inter vivos trust, no beneficial interest in which was acquired for consideration payable directly or indirectly to (i) the trust, or (ii) any person who has made a contribution to the trust by way of transfer, assignment or other disposition of property, and, for the purposes of (b) above and paragraph 53(2)(h), where an inter vivos trust is created by way of the transfer, assignment or other disposition of property by an individual (or two or more individuals each of whom was, at the time the trust was created, related to each of the other individuals), any beneficial interest in the trust acquired by such individual (or such individuals) at the time the trust was created shall be deemed to have been acquired for no consideration. ...

However, where such a debt was of a kind that would have qualified for consideration as a bad debt had it been retained until the end of the taxation year, any loss at the time of its disposition, or later because of non-payment by the debtor, would normally be deductible by the taxpayer as a general business expense. ... A taxpayer who is in the money-lending business, as in the case of any other taxpayer, may make loans that are not prompted by the ordinary considerations that govern the making of loans in a money-lending business. 13. ... Although the length of time that an account is in arrears is generally an important consideration in deciding whether the account is doubtful of collection, in certain circumstances a lengthy delay may occur without the account being so considered. ...

A gift, for purposes of sections 110.1 and 118.1, is a voluntary transfer of property without valuable consideration. ... Any payment which might be considered in excess of the fair market value of the price of admission for the event is presumed to be consideration for participation in the lottery or draw. ¶  9. ... New ¶  9 incorporates a comment from the former ¶ 3(b) and notes that while generally a legal obligation to make a donation would cause the donation to lose its status as a gift, there are exceptions when the obligation is entered into voluntarily and without consideration. ...

The amount of the benefit, if any, is: the fair market value of the consideration received by the non- arm's length transferee for the rights Minus: any amount paid by the employee for those rights. ... " The word "issue" means to deliver unissued shares of a corporation, including to deliver unissued shares for no monetary consideration. ... Forward participating shares are generally those shares of a separate class of a corporation that are purchased by the individual for fair market value consideration. ...