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25 August 2009 Internal T.I. 2009-0333751I7- Apprenticeship Training Tax Credit Unedited CRA Tags s. 89, 38, 96 and 97 of the TA XXXXXXXXXX 127(9) Principal Issues: Can an expenditure be taken into consideration for multiple purposes in computing the Ontario Apprenticeship Training Tax Credit, any of the Ontario research and development tax credits and the federal investment tax credit? ... IT Rulings document 2008-0285401C6 clarifies that an expenditure which qualifies both as a scientific research and experimental development expenditure under section 37 of the Income Tax Act ("ITA") and an apprenticeship expenditure under subsection 127(9) of the ITA may be taken into consideration twice for the purposes of computing investment tax credits at the end of a taxation year. ...

Under subparagraph 160(1)(e)(i), the amount is the excess of the fair market value of the property transferred over the fair market value of the consideration given for the property. ... Under paragraph 325(1)(d), the amount is the excess of the difference of the fair market value of the property transferred net of the consideration given for it, and any amount assessed for income tax. ...

You have advised us that the prospector had previously entered into an agreement with a corporation whereunder the prospector disposed of a mining claim to the corporation, and as consideration therefor, received a right to receive blocks of shares of the corporation over several years. ... Our Comments Subsection 35(1) of the Act applies where shares of a corporation are received in a taxation year by an individual who is a prospector as consideration for the disposition to the corporation of an interest in a right, licence or privilege to prospect, explore, drill or mine for minerals in a mineral resource in Canada, or Canadian real property the principal value of which depends upon its mineral resource content where such property was acquired as a result of the individual's efforts as a prospector. ...

Proposed amendments to the Act will allow the transfer of property to qualify as a gift, for tax purposes, in certain circumstances where a donor has received consideration for property transferred to a charity or other qualifying donee after December 20, 2002. ... Proposed subsection 248(32) provides that the amount of the advantage is generally the value, at the time the gift is made, of any property, service, compensation or other benefit received, or expected to be received in the future, by the donor as partial consideration for, or in gratitude for the gift. ...

A accepts a promissory note (the "Farmco Note") in the amount of $100,000 from Farmco as consideration in respect of Mr. ... The Farmco Note, accepted in exchange for the transfer of accounts receivable, represents consideration paid to, and an amount received by, Mr. ...

Reasons: Whether all of the conditions of 20(1)(e.2) are satisfied is a question of fact to be determined in consideration of all pertinent information. 2008-030396 XXXXXXXXXX Robert Demeter, CGA (613) 952-1505 March 10, 2009 Dear XXXXXXXXXX: Re: Deduction of premiums on life insurance used as collateral We are writing in response to your recent request regarding the above-noted subject. ... Whether the conditions described by paragraph 20(1)(e.2) are present in any particular situation is a question of fact that must be determined in consideration of all pertinent information. ...

If however, the option to purchase is exercised and the grantor disposes of the real property that constitutes QFP, it is our view that, pursuant to subsection 49(3) of the Act, the consideration received by the grantor for the option will become part of the proceeds of disposition of the real property. As such the consideration for the option may be eligible for the capital gains exemption under section 110.6 of the Act by virtue of being reflected in any taxable capital gains arising from the disposition of the real property. ...

In order to qualify, the amounts must be paid as a premium, contribution or other consideration to a private health services plan ("PHSP"). ... In this respect the plan must contain the following basic elements: (a) an undertaking by 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. ...

A gift is generally defined as a voluntary transfer of property without consideration. In the scenario you have described, there is consideration in the form of services provided to the estate. ...

A disposes of his 100 common shares of the capital stock of XCO in favour of YCO for a sale price of $800, the sole consideration consisting of a promissory note issued by YCO, payable on demand to Mr. ... Our comments: It is our view that, in a situation such as that described above, where the FMV of the shares transferred is higher than the FMV of the consideration received, the amount of the deemed dividend determined under paragraph 84.1(1)(b) would not be affected or increased because of the application of subparagraph 69(1)(b)(i) to the transaction. ...