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Company A would then transfer the property to Company B under subsection 85(1) and receiver preferred shares in consideration for it. ...

In other cases, consideration of all verbal and written representations made in connection with the particular offering would be necessary in order to determine the applicability of subparagraph 237.1(1)(a)(ii). ...

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

7 October 1991 Income Tax Severed Letter- Determination of residence for an testamentary trust Unedited CRA Tags none Subject: Determination of Residence for an Testamentary Trust As discussed with Carol Abbass of your office, we are enclosing a letter dated September 19, 1991 from XXX concerning the determination of residence for the XXX for your consideration and reply. ...

In that the tax implications that flow from a reciprocal arrangement cannot be determined independent of the actual documentation including agreements between the members, we would recommend that, should you be contemplating a specific arrangement, consideration be given to obtaining an advance income tax ruling. ...

IF ANY PARTICULAR TRANSACTION IS THOUGHT NOT TO BE IN ACCORD WITH THE INTENT OF THE LEGISLATION THE DEPARTMENT'S CONCERNS ARE MADE KNOWN TO THE APPROPRIATE OFFICIALS AT THE DEPARTMENT OF FINANCE FOR CONSIDERATION OF CORRECTIVE AMENDMENTS. ...

En conséquence, nous avons transmis votre demande à cette dernière division pour sa considération. ...

We enclose copies of related correspondence for your consideration. In order that the Remission Committee may be able to consider the matter and apply the guidelines in TOM 2263.22, would you please submit to this Division a report containing the information required under TOM 2263.24(2)(A) to (G). ...

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. ...

We offer for your consideration the following comments: Question A-8 In reply to the second concern raised in this question, RCT practice conforms to the Departmental response. ...