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The reference in 73(3) to "... eligible capital property in respect of a business carried on in Canada by a taxpayer... ...

You made reference to the fact that the IRS in the United States are treating such expenditures as being on account of capital, according to a published article in The Financial Post, dated November 25, 1992 which reads, in part, "... new IRS ruling prohibiting the deduction of costs associated with asbestos removal... ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Consequently, its four founding shareholders currently own the common shares of Lossco as follows: Shareholder # of common shares Country of Residence Profitco XXXXXXXXXX Canada Forco1 XXXXXXXXXX United States XXXXXXXXXX ("Forco2") XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX ("Forco3") XXXXXXXXXX XXXXXXXXXX Profitco's aggregate adjusted cost base and aggregate paid-up capital attributable to its XXXXXXXXXX common shares of Lossco is $XXXXXXXXXX. 5. ...

Dans l'arrêt Younoman (86 DTC 6584), ces actionnaires bénéficiaient de l'usage exclusif d'une résidence d'un coût de tout près de 400 000 $. ...

Background 24(1) 24(1) Black's Law Dictionary defines payable as "a debt that is fixed and certain but the day for its payment has not arrived" and defines due as " a debt that is presently matured and enforceable". ...

Bien que M. et Mme & avaient-les mêmes droits, il n'était pas dans leur meilleur intérêt de liquider Speedway Inc., parce qu'ils n'auraient eu droit alors qu'a un avoir minime. ...

., [[1970] C.T.C. 264] 70 DTC 6199, has stated that a "mine", insofar as mineral resource mines are concerned, should not be interpreted to mean "a portion of the earth containing mineral deposits", instead, it should be taken to mean " a mining concern taken as a whole, comprising mineral deposits, workings, equipment and machinery, capable of producing ore". ...

While we agree that the series of transactions may not, for the purposes of subparagraph 55(3)(a)(i) of the Act, result in a disposition of any property to a person with whom NEWCO deals at arm's length, it is our opinion that the series of transactions will, for the purposes of subparagraph 55(3)(a)(ii) of the Act, result in a "... significant increase in the interest in any corporation of any person with whom the Corporation that received the dividend was dealing at arm's length". ...

Simmonds & Sons Limited v. M.N.R., [[1990] 1 C.T.C. 2087] 89 DTC 707 (TCC), Mr. ...