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The non-resident trust which is exempted from the application of subsection 94(1) by virtue of subclause (b)(i)(A)(III) therof, will derive all of its income from assets that will be sold to the trust by the immigrant for fair market value consideration in the form of a non-interest bearing promissory note payable on demand.  ...

After careful consideration of the taxpayer's arguments set out in your memorandum and consultation with officials of the Department of Finance, we agree with you that the 24(1) are "clubs" within the ordinary meaning or that term and that their primary purpose is to provide recreational facilities for their members. ...

For specific consideration of your situation, it should be referred to your local District Taxation Office together with all relevant details including an identification of the employee involved. ...

In view of the foregoing, we request that you give further consideration to processing the taxpayer's 1986, 1987 and 1988 returns on the administrative basis described in this memorandum and its related Schedules "A" and "B". ...

Day Chief of Verifications (613) 957-2136 and Collections   902923 SUBJECT:  19(1) (the "taxpayer") Disposition of Principal Residence As discussed with you, we are forwarding, for your consideration and reply, a request for an advance income tax ruling submitted on the taxpayer's behalf by  19(1) As indicated in the attached reply to 19(1) the requested ruling cannot be given since the transaction has been completed. ...

Upon further consideration, we have concluded that the full amount of the Benefits must be brought into income under the provisions of subparagraph 56(1)(a)(i) of the Act but an offsetting deduction for 1/2 of the amount would be allowed under subparagraph 110(1)(f)(i) of the Act for the amount not taxable under the Convention.  ...

This position was apparently based on two considerations: 23 21(1)(b) As a result of 1985 amendments to section 84.1 which have removed the policy concerns referred to above, and the 1988 Tax Court of Canada decision in Estate of Karna Mav v. ...

Nous avons réexaminé le guide en question et avons relevé d'autres points que vous pourriez prendre en considération. ...

In this situation, the payer corporation has provided valuable consideration with no reasonable expectation of repayment.  ...

Please note that, in the majority of corporations' certificates of constitution, the share legal rights would provide for the payment upon redemption, repurchase or liquidation, of an amount equal to the consideration for which the share has been issued and any amount of dividends declared and not paid. 21(1)(b) R.J.L. ...