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

The above factors would be taken into consideration in determining the deductibility of expenses for any individual participant on a case-by- case basis. ...

On your behalf, I will ensure that the Saskatchewan Ministry of Revenue is provided with information necessary for their consideration of a remission of provincial income tax. ...

In our view, there is nothing to prevent a District Taxation Office or Taxation Centre from referring a case to the Head Office Appeals Branch for their consideration in accordance with paragraph 14 of Information Circular 80-7 dated June 30, 1980. ...

Thornley (613) 957-2130 February 28, 1986 Dear XXXX Re: Capital Dividend Account This is in reply to your letter of December 11, 1985 concerning whether or not a capital gain reserve that is to be brought into income at the end of the taxation year should be taken into consideration in the calculation of the Capital Dividend account that may be calculated at any particular time in the year. ...

This matter has previously been referred to MaryLove day of your division for consideration. 19(1) principal concern is that the Department is not administering the tax law with respect to non-registered annuities consistently. ...

The Ontario Ministry of Revenue will be provided with the information necessary for their consideration of a remission of provincial income tax. ...

Pursuant to the definition of qualified property, the relevant consideration is the primary purpose for which an asset is acquired, and the vessels referred to apparently were not acquired to be used in Canada primarily for the purpose of fishing. 21(1)(a) for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Upon receipt of the above information, active consideration will be given to your ruling request. ...

All statutory references are to the Act unless otherwise stated. 24(1) While the income tax implications with respect to any particular arrangement can only be determined after consideration of the specific facts we are able to provide you with the following general comments. ...