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SUBJECT: TERM PREFERRED SHARE SECTION: 112(2.1)] 1992 Corporate Management Tax Conference TERM PREFERRED SHARES Question 12 Will the Department, following the 1991 Tax Court of Canada decision in the Société d'Investissement Desjardins case [[1991] 1 C.T.C. 2214] (91 D.T.C. 393), take into consideration as one of the relevant factors in establishing whether particular term preferred shares were or were not acquired in the ordinary course of the business carried on by a corporation the fact that the corporation is a specified financial institution only by reason of being related to a financial institution and is not itself engaged in a financing business? ...

After careful consideration of the matters raised, I regret that the measure of relief that you are seeking from tax arising from XXX The Income Tax Act does not permit the deduction of XXX. ...

However, after careful consideration of the matters outlined in his letter, I regret that I am unable to recommend the remission of his tax penalty or interest liability. ...

This matter has previously been referred to Mary Loveday of your division for consideration. ...

Curley, Chief of Verifications and Collections in our Hamilton District for his consideration. ...

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

If you are concerned about a specific situation, you may refer the matter with any relevant documentation to the District Taxation Office for their consideration. ...

The same consideration applies with respect to GIC issued by a trust company. ...

Your recommendation to amend proposed subsection 248(21) to ensure that disproportionate distributions will be provided relief similar to that provided to proportionate distributions is a policy consideration for the Department of Finance. ...

The matter was referred to this office for consideration and reply. We apologize for the delay. ...