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In determining whether this exception is applicable, a consideration is whether an individual receives a benefit under a PHSP in his or capacity as an employee or as a shareholder. ...

The above situation, which was referred to your division by XXXXXXXXXX Tax Services, involves a consideration of paragraph 81(1)(h) of the Income Tax Act (the Act) which exempts social assistance payments made to a caregiver in certain circumstances. ...

" The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...

Nevertheless, to determine whether it applies, consideration must be given to the fact that dividends were not paid on shares of "a corporation" in preceding taxation years, other than prescribed shares. ...

These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...

We are aware that it is not uncommon for the use of automobiles to be provided in exchange for non-cash consideration such as goods, services or certain rights and privileges. ...

The representative's correspondence dated January 11, 1995, claimed that it was departmental practice to accept late filed subsections 104(13.1) and (13.2) designations and quoted the following excerpt from document number 912157 originating from Rulings dated September 24, 1991: "The Division stressed that the adoption of any such practice...would be solely administrative in nature and would take into consideration the intended purpose of the late designation as well as any hardship that might be encountered by the trustee or beneficiaries if the late designation were not accepted. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX, as described in more detail below: XXXXXXXXXX. 7. ...

One unit will be issued to the Company on the establishment of the Fund for consideration of $XXXXXXXXX. 5. ...

The statutory provision under consideration sets out a rule to determine a taxpayer's capital gain from the disposition of property and only expenses or outlays to be applied in reducing the gain are those incurred or made directly for the purposes of making the disposition. ...