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Further, in order for an expenditure or transfer of property to be considered a gift, it must be made without conditions, from detached and disinterested generosity, out of affection, respect, or charity or like impulses, and not from the constraining forces of any moral or legal duty. ...

Generally, if you were obligated to pay an amount owed by a small business corporation, and that corporation was still in existence at the time, the corporation is considered to have incurred a debt to you for the amount paid. ...

Furthermore, in order for a particular entity to be considered such an Agent of the Crown, the law creating the entity must expressly make it an Agent of the Crown or it must be an Agent of the Crown at common law. ...

We will refer your letter to our Publications Division so that your concern can be considered in a future revision of IT-114. ...

Shinerock (613) 593-6937 May 20, 1982 Dear XXXX We refer to your letter of March 29, 1982 in which you requested clarification of our position on the time when dividends are considered to have been paid for the purpose of the special tax of 12.5% on dividends paid after November 12, 1981. ...

In the attached memo dated December 6, 1984, your Division adopted the view that employees are not considered to have received a taxable benefit from such bridge financing where the loan was for the amount of equity in the employee's former home. ...

The proposed investment will be considered qualified for the purpose of an RRSP only if 1) the mortgage is administered by an approved lender under the National Housing Act; 2) the mortgage is insured under the National Housing Act or by a corporation offering its services as an insurer of mortgages; and 3) the mortgage has a normal commercial interest rate and terms and is administered as though the property were owned by a stranger. ...

In our opinion, the U.S. property would be considered to have been used by the taxpayer in the course of carrying on the business of farming in Canada since the "property (the Canadian farm property) for which the real property (the U.S. farm property) was substituted was used" by the taxpayer "in the course of carrying on a business of farming in Canada". ...

It is the Department's administrative policy that things mailed in a foreign country are considered to be received by the Department on the date of the foreign postmark for the purposes of subsection 248(7) of the Act provided (a) the item is mailed in a foreign country by a person who resides in that country and the item mailed pertains to that person's income tax affairs, and (b) the item is mailed with all due dispatch (first class air mail or equivalent). ...

For the Department's views on the criteria considered in determining a corporation's principal business, you may refer to Interpretation Bulletin IT-290. ...