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Any exceptions to the above position could only be considered on a case by case basis and after consideration of all of the relevant facts. ...

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. ...

As the Department of Finance is responsible for the formulation and development of tax policy, you may wish to bring. the matter to the attention of that Department for consideration. ...

You requested our comments whether losses arising from loan guarantees given by the above corporation on behalf of U.S. corporations which it controls, for no or inadequate consideration, would be deemed to be nil by subparagraph 40(2)(g)(ii) of the Income Tax Act (the "Act") on the basis that the guarantees were not given for the purpose of gaining or producing income. 23 21(1)(b) 000263 Accordingly in our view 24(1) The exception in paragraph 6 of IT-239R2 and paragraph 7 was established to address specific tax policy concerns. ...

You question whether the word "person" includes a partnership, for the purposes of section 54.2 of the Act, where a partnership has disposed of property that consisted of all or substantially all of the assets used in an active business carried on by that partnership to a corporation for consideration that includes shares of the corporation. ...

However, we do offer the following general observation for your consideration. 1. ...

The reassessment was based in part upon our memorandum of July 15, 1986, to the District Office, a copy of which is enclosed with related materials for your consideration. ...

A determination of from what shares derive their value or the greater part of their value is essentially a question of fact that can only be determined after consideration of all relevant facts including the manner in which the various assets of the company have been financed. ...

The entitlement takes the form of a current salary distribution and you ask whether this dividend-equivalent, right would disqualify the plan from consideration as a prescribed plan under Regulation 6801(d). ...

On behalf, I will ensure that the Ontario Ministry of Revenue is provided with the information necessary for their consideration of a remission of provincial income tax. 24(1) the Receiver General and address your letter to Mr. ...