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Total compensation received: $1,500,000 Compensation for land and building: $1,200,000 Compensation for moving equipment: $ 300,000 Is the equipment considered to have been expropriated? ... Paragraph 20 mentions that "The compensation award determined by the expropriating authority may take into account, in addition to the fair market value of any expropriated property, several other factors such as: (...) costs of relocation, including moving costs (...) may form part of the proceeds of disposition of the property disposed of. ... "...for the purpose of gaining or producing income from the business or property ". ...

This ruling replaces and rescinds Ruling # 2000- 005024, dated XXXXXXXXXX, 2000. ... The remaining XXXXXXXXXX % membership interest in XXXXXXXXXX is owned by XXXXXXXXXX, an arm's length third party. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

B 1 common share 1 common share FMV = $1,000 FMV = $1,000 OPCO In the above example, Opco issues another share to Mrs. ... FINANCIAL CONTRIBUTION When a partnership is formed, it often happens that one partner contributes knowledge or personal know-how while the other partners contribute their financial resources to the partnership. ... However, the exception does not apply to buildings including a permanent R & D infrastructure. ...

This ruling replaces and rescinds Ruling # 2000- 004652, dated XXXXXXXXX, 2001. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

30 October 1992 Income Tax Severed Letter 2M0333A- Published Version of 1991 Canadian Tax Foundation Unedited CRA Tags 30 / Various / Divers Revenue Canada Round Table Table Ronde de Revenu Canada* Robert M. ... Unless otherwise stated, statutory references in this panel are to the Act. 4 ``Revenue Canada Round Table,'' in Report of Proceedings of the Thirty-Third Tax Conference, 1981 Conference Report (Toronto: Canadian Tax Foundation, 1982), 726-66, question 23, at 743-44. 5 Ibid. 6 Bill C-18, An Act To Amend the Income Tax Act, the Canada Pension Plan, the Cultural Property Export and Import Act, the Income Tax Conventions Interpretation Act, the Tax Court of Canada Act, the Unemployment Insurance Act, the Canada-Newfoundland Atlantic Accord Implementation Act, the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act, and Certain Related Acts, first reading May 30, 1991. 7 ``Revenue Canada Round Table,'' in Report of Proceedings of the Forty-Second Tax Conference, 1990 Conference Report (Toronto: Canadian Tax Foundation, 1991), 50:1-68, question 26, at 50:15. 8 Interpretation Bulletin IT-258R2, May 11, 1982. 9 Interpretation Bulletin IT-260R, November 12, 1979. 10 Interpretation Bulletin IT-64R2, December 20, 1983. 11 Interpretation Bulletin IT-243R3, May 21, 1985. 12 88 DTC 6525; [[1989] 1 C.T.C. 66] (1989) 1 CTC 66 (FCTD). 13 Supra footnote 7, question 22, at 50:12-13. 14 Supra footnote 10. 15 Interpretation Bulletin IT-147R2, June 19, 1985. 16 Interpretation Bulletin IT-486R, December 31, 1987. 17 Canada, Department of Finance, Release, no. 90-171, December 20, 1990. 18 Information Circular 76-19R, November 13, 1978. 19 Information Circular 76-19R2, June 15, 1990. 20 ``Revenue Canada Round Table,'' in Report of Proceedings of the Thirty-Eighth Tax Conference, 1986 Conference Report (Toronto: Canadian Tax Foundation, 1987), 51:1-88, question 62, at 51:30. 21 Supra footnote 4, question 42, at 757-58. 22 ``Revenue Canada Round Table,'' in Report of Proceedings of the Thirty-Sixth Tax Conference, 1984 Conference Report (Toronto: Canadian Tax Foundation, 1985), 783-847, question 82, at 839-40. 23 Supra footnote 4, question 42, 757-58. 24 Supra footnote 7, question 56, at 50:29-30. 25 SO 1982, c. 4, as amended. 26 Interpretation Bulletin IT-454, August 11, 1980. 27 Interpretation Bulletin IT-417R, July 5, 1982. 28 Interpretation Bulletin IT-206R, October 29, 1979. 29 ``Revenue Canada Round Table,'' in Report of Proceedings of the Forty-First Tax Conference, 1989 Conference Report (Toronto: Canadian Tax Foundation, 1990), 45:1-60, question 38, at 45:22-23. 30 The Queen v. ...

XXXXXXXXXX There are XXXXXXXXXX FCo XXXXXXXXXX Shares; “eligible property” has the meaning assigned by subsection 85(1.1); “ First Act ” means the Canada Business Corporations Act; “First Exchange” means XXXXXXXXXX; “forgiven amount” has the meaning assigned by subsections 80(1) and 80.01(1); “Fund Trustees” means a group of XXXXXXXXXX persons who will be elected by Unitholders in accordance with the Fund Declaration of Trust to act as trustees of New Fund, subject to the terms of the XXXXXXXXXX Agreement. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate XXXXXXXXXX ...