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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. 24(1) I am satisfied that 19(1) has been treated in a fall and reasonable manner similar to any taxpayer in like circumstance. ...

We recommend that this case be handled on a priority basis in view of the length of time it has already been under consideration by the Department. ...

The above comments are of a general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

Thus the fair market value of goodwill that is a part of the business, whether or not it was purchased, is required to be taken into consideration in this determination. ...

As such, the CCA classes of assets in the a terminal should be determined on an individual basis giving consideration to both the specific use that is made of the asset and the degree of connection to or integration with other assets used for an identifiable function in which the asset is used. ...

However, we will outline in general terms certain considerations which may be relevant. ...

It should be noted that the characterization of a payment for income tax purposes must be based on consideration of all relevant facts and may differ from the terminology used in a specific contract. ...

You stated that the purchase price of the assets to be transferred as outlined in the agreement will be fair market value and the consideration will be (a) a promissory note equal to the adjusted cost base of the assets being transferred, and (b) a subsequent issue of special shares having a paid-up capital of $1 and a redemption and retraction amount equal to the difference between the fair market value of the assets being transferred and the fair market value of the note. ...

A determination of from where shares of a company derive their value or the greater part of their value is essentially a question of fact to be determined after consideration of all relevant facts including the manner in which the assets of the company are financed. ...

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. ...