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Section 84.1 achieves its purposes by: (1) reducing the paid-up capital of the shares of the subject corporation, which reduces the ability to return paid-up capital of the purchaser corporation as the excess would be taxed as a dividend, and (2) deeming the individual shareholder to have received a dividend where the purchaser corporation pays non-share consideration for the shares of the subject corporation that exceeds the greater of the paid-up capital and the “hard ACB” of the particular shares transferred. ...

As stated in paragraph 3 of Interpretation Bulletin IT-110R3, a gift is a voluntary transfer of property without valuable consideration. ...

Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

Your suggestions on the improvements of the guides and bulletins relating to principal residences and the transfer or loan of properties have been forward to the appropriate sections for consideration in the next revision of the relevant documents. ...

Where an individual pays fees with respect to circumstances where the individual considers himself or herself to have been wrongfully dismissed, the determination of the extent that the fees are deductible normally involves a consideration of paragraphs 8(1)(b) and 60(o.1) of the Act. ...

Application for "approved association" In order that an association or organization may obtain "approved" status, it is necessary that certain information and documents in respect of the association be submitted to this Directorate for consideration and approval. ...

The Investment Restrictions will include restrictions that: (e) Newco may make no investments other than investments that a pension fund or plan is permitted to make under the XXXXXXXXXX; (f) at all times, at least 98% of its assets must consist of cash and investments; (g) at no time may it issue a debt obligation or accept deposits; and (h) in each taxation year, it must derive at least 98% of its income from, or from the disposition of, investments. 5.Newco will enter into a management agreement with XXXXXXXXXX pursuant to which XXXXXXXXXX will present appropriate investment and divestment opportunities to Newco for its consideration and render certain management and administrative services and facilities to Newco. ...

Such proposals have not been taken into consideration in this response. ...

Micheline Aucoin at the Canadian Embassy in Bonn, has been forwarded to us for consideration and reply. ...

Whether bona fide arrangements were made at the time the housing loan was made, for repayment of that loan within a reasonable period of time, is a question of fact that can only be determined upon consideration of all the circumstances of a particular taxpayer's case. ...