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If an unresolved issue has been referred to the Ministers described in clauses 39 or 40, those Ministers may refer the issue to a third party for consideration and advice.... ...

The statements in the Willingale case that discounts did not accrue from day to day may have been influenced by the consideration that the taxpayer bank could, and sometimes did, sell the debt obligations before maturity. ...

The Explanatory Notes state that "the CRIC must reasonably allocate the consideration paid for the Canadian target corporation to the foreign affiliate shares in order to determine the appropriate consequences under subsection 212.3(2). ...

Statements in tax returns that "were not made inadvertently but only made following due consideration and professional advice... constitute statements against interest" (Riviera Hotel). ...

That, in addition to consideration of the taxpayer's whole course of conduct while in possession of the asset, is what in the end generally influences the finding of the Court. ... ") Perhaps on this basis or on the basis that the transfer of a property to an affiliate in consideration for securities of the affiliate may be characterized merely as a change in the form of ownership by the taxpayer of the transferred property (see Krauss), properties transferred (perhaps on a rollover basis) to an affiliate often may retain their character as such in the hands of the transferee as capital property or inventory (see " Reorganization transactions ", 2000 Ruling, Mara Properties), and with disposition occurring on capital account to the transferor. ...

The proceeds in 1 do not include the fair market value of shares of another foreign affiliate of the taxpayer that were acquired by the recipient corporation as consideration for the disposition and as an exempted investment under s. 212.3(16) or (18) applies, or proceeds from a disposition of shares to a corporation resident in Canada where such acquisition of the shares is an investment exempted by s. 212.3(16) or (18). ... FA1 sells its shares of Canco to CRIC in consideration for a $20 note. ...