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12 December 1989 External T.I. 58895 F - Interpretation of subparagraph 50(1)(b)(iii)

The comments set out in this letter are of a general nature only and do not take account of considerations that might arise in the context of specific transactions or events. ...

6 September 1991 Ruling 91M09183 F - Offshore Trust

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. ...

14 February 1990 Administrative Letter 74626 F - Admissibility of Universal Life Policies as Charitable Donations

However this is a question of fact, that can only be determined after consideration of the circumstances of a particular situation. ...

16 December 1990 External T.I. 903395 F - Sale of Property

A recent legal opinion suggested that there is a reasonable argument that the assumption of a mortgage by a recipient foundation would constitute "consideration", being a benefit to the donor to the extent that he is relieved of responsibility for the debt. ...

11 January 1991 External T.I. 9032355 F - Consequences of an RRSP Trust Becoming a Mortgagee in Possession

Instead, we would ask that you address your concerns to your local District Taxation Office for their consideration. ...

23 February 1990 Internal T.I. 9214029 F - Remission of Tax

However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of taxes paid as a result of the 24(1) The law restricting the purchase of an IAAC became effective after November 12, 1981. ...

24 May 1991 External T.I. 9109915 F - Capital Gain Deduction - Disposition of Property

The calculation of safe income involves consideration of many factors, some of which were not dealt with in your submission. ...

27 August 1990 Internal T.I. 901877 F - Non-profit Organizations

An organization's status for purposes of paragraph 149(1)(1) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...

3 January 1991 Internal T.I. 902429 F - Calculation of Non-capital Loss

After careful consideration of the matter and consultation with Current Amendments Division and Legal Branch, we have concluded that an individual may claim a capital gains deduction under section 110.6 in computing taxable income, notwithstanding the fact that there is insufficient net income to absorb the deduction. ...

11 January 1990 Ruling HBW4125U31 F - Permanent Establishment in Canada of Non-resident Corporation

Normally, in making such a determination, the Department would give consideration to the commentary on paragraph 3 of Article V in the Model Double Taxation Convention On Income and On Capital-Report of the OCED Committee on Fiscal Affairs 1977. ...

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