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Consequently, this question should be addressed to the appropriate Tax Services Office for its consideration. ... The determination of whether a specific individual qualifies for the exemption from income taxes should be addressed to the appropriate Tax Services Office for its consideration of the application of Guideline 1. ...

As consideration for the property, Vendor receives a note receivable ("Original Debt") from Purchaser that is payable in the following year. 2. ... Vendor receives a note receivable ("Exchanged Debt") from A Ltd. as consideration for the transfer. ...

A will transfer all his Aco shares to another corporation resident in Canada ("Bco") owned by him taking back non-share consideration equal to his adjusted cost base ("ACB") of the Aco shares and shares of Bco such that the total amount of consideration Mr. ...

Holdco will transfer all of the shares of USCos which it presently owns to USHoldco in exchange for shares of USHoldco and no other consideration, pursuant to subsection 85.1(3) of the Act. 4. Each of Aco, Bco, and Cco will transfer the shares of the LLCs currently owned by Aco, Bco and Cco, respectively, to USHoldco in exchange for shares of USHoldco and no other consideration, pursuant to subsection 85.1(3) of the Act. ...

In the situation under consideration, a corporation redeems certain of its preferred shares and, as consideration for the redemption, assumes a bank loan owed by the redeeming shareholder. ...

Reasons FOR POSITION TAKEN: This settlement appears to be "an amount...received....in recognition of the taxpayer's long service, or...in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgement of a competent tribunal", as the MOA indicates, in part, that the former employer agrees to pay the former employee $XXXXXXXXXX inclusive of severance monies less all necessary statutory source deductions, in consideration for the withdrawal of the former employee's grievance against his former employer and the resignation of the former employee effective XXXXXXXXXX. ... The MOA indicates, in part, that the former employer agrees to pay the former employee $XXXXXXXXXX inclusive of severance monies less all necessary statutory source deductions, in consideration for the withdrawal of the former employee's grievance against his former employer and the resignation of the former employee effective XXXXXXXXXX. ...

Generally, a plan will be considered a superannuation or pension fund where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodical payment on or after the employee's retirement in consideration for his or her employment services. ...

As consideration, Newco assumes the liabilities of Targetco and issues shares to Targetco. ... Purchaseco acquires all of the shares of the capital stock of Newco from Targetco for fair market value consideration. 9. ...

Ruling K(i) is cancelled and replaced as follows: "(i) the shares of each Child's Investco which are to be issued to the particular Child and/or the Bare Trustee (on behalf of the particular Child), as the case may be, as described in 11, 12, 13 and 14 above, as consideration for the transfer of their respective shares of Holdco which are to be issued to the particular Child and/or the Bare Trustee (on behalf of the particular Child), as the case may be, as consideration for the transfer of their respective grandfathered shares of Aco that were owned by each such individual, as described in 10 above, to be the same shares as the grandfathered shares of Aco owned by each such individual for the purpose of paragraph 131(11)(b) of S.C. 1998, c. 19; and" Notwithstanding the above noted changes to the proposed transactions and ruling K(i), we confirm that, subject to the conditions set out therein, the rulings given in the Ruling, as amended above, will continue to be binding on the Canada Customs and Revenue Agency ("CCRA") in accordance with the practice outlined in Information Circular 70-6R3, dated December 30, 1996, provided that all the proposed transactions are completed in the manner described in the Ruling, as amended herein, before XXXXXXXXXX. ...

REASONS: Inducement Costs represents rights relating to leases in respect of the property transferred in the butterfly and the consideration paid for these rights should be deductible by the transferee corporations (See Ruling 3-980098). ... As consideration for the assignment of the benefit of the Inducement Costs, each of XXXXXXXXXX /Bco and Newco will assume a portion of the Liabilities with a principal amount equal to the amount of the benefit of the Inducement Costs assigned to XXXXXXXXXX /Bco or Newco, as the case may be. ...