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Rather than arbitrate comments made regarding the contents or positions taken in our memorandum, we will make additional comments in an attempt to clarify some of the misconceptions that exist mainly because of the involved nature of the transactions under consideration. ... Should he choose the C option to pay the debt in $9,000 monthly payments for total consideration of $540,000, the additional $40,000 could be treated as finance charges as could the additional $10,000 in payment option B. ...

In the Department's view, the guidelines set out in this Interpretation Bulletin are a reasonable distillation of the relevant considerations developed by the Courts. ...

Blair Sixsmith, Assistant Director of Verification, Enforcement, Vancouver Tax Services Office, 15th Floor, 1166 West Pender Street, BC, V6E 3H8 for his consideration. ...

Blair Sixsmith, Assistant Director of Verification, Enforcement, Vancouver Tax Services Office, 15th Floor, 1166 West Pender Street, BC, V6E 3H8 for his consideration. ...

It was your suggestion that the use of a "residency analysis" by the Department could take into consideration these facts. ...

It was your suggestion that the use of a "residency analysis" by the Department could take into consideration these facts. ...

Munir Sheikh, Assistant Deputy Minister, Tax Policy Branch, Department of Finance, for his consideration. ...

After consideration of the connecting factors, the Court found that the performance of Ms. ...

In formulating our reply as outlined above, consideration was not given to the application of other provisions of the Act, such as section 84.1 to the transaction described in paragraph 4 above or subsection 55(2) to the transaction described in paragraph 8 above, which apply in a specific situation involving the disposition of shares. ...

Newco would redeem the Newco Preferred Shares in consideration for the redemption by Opco of the Opco Preferred Shares (the "cross-cancellation"). ...