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In this regard, I have forwarded a copy of your letter and our correspondence to the Honourable Paul Martin, Minister of Finance, for his consideration. ...

I note that the Prime Minister's office also sent a copy of your August 14, 1999 letter to the Honourable Paul Martin, Minister of Finance, for his consideration. ...

In determining whether a loan was made by virtue of an office or employment, the Department will take into consideration any involvement or assistance by his employer in obtaining the loan, including (a)     involvement in negotiation of the loan, (b)     guaranteeing repayment of the loan principal or interest, (c)     recommending in writing to the lender that the loan be made, (d)     agreement in writing before the loan is made, to assist with the cost of the interest either by direct reimbursement to the borrower for all or part of it or by paying such interest directly to the third party lender, or (e)     providing the individual with a letter of introduction to a mortgage lender explaining the amount and terms of the mortgage interest subsidy which the employer will be making to the employee. ...

We have reviewed the draft documents and offer the following comments for your consideration. ...

It was also unclear from the facts presented whether the transaction took place at fair market consideration or whether the interest charged was at a rate equal to or greater than the applicable prescribed rate or a rate that would have been agreed upon between parties dealing with each other at arm's length. ...

To obtain any other result would require an amendment to the Act, consideration which is the responsibility of the Department of Finance. ...

In this regard, paragraph 3 of Interpretation Bulletin IT-110R2 indicates that a gift is a voluntary transfer of property without valuable consideration.  ...

Should you have a factual situation involving an actual taxpayer that you wish to have considered, you should forward all relevant facts and documentation to the appropriate district taxation office for their consideration. ...

Aux fins de déterminer si des opérations ou événements sont liés, il faut prendre en considération tou1s les faits selon les circonstances. ...

You requested our comments regarding the application of subsection 55(2) of the Act in the following hypothetical circumstances. (1)     Opco is a Canadian-controlled private corporation and  a taxable Canadian corporation within the meanings of paragraphs 125(7)(b) and 89(1)(i) of the Act, respectively. (2)     The common shareholders of Opco are married individuals owning 65 per cent and 35 per cent of the issued shares respectively. (3)     The corporation has a fair market value of $1,000,000 represented by $800,000 of active business assets and $200,000 cash. (4)     The corporation has accumulated $500,000 in safe income for the purposes of subsection 55(2) of the Act. (5)     The shareholders intend to sell 50 per cent of each of their shareholdings to an arm's length party for $500,000. (6)     Before the intended sale, a new company ("Newco") is incorporated, and the spouses transfer one half of their respective shares of Opco to Newco pursuant to the provisions of subsection 85(1) of the Act and receive common shares of Newco as consideration.  ...