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. … The US connections required by s.269B are limited to a) stapling of more than 50% by value of the foreign corporation's shares to those of a domestic corporation, and b) direct or indirect ownership as to 50% or more by US persons. ...

They accomplished what section 160 sought to prevent – its application, they defeated its underlying rationale, and they circumvented its application. ...

Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

Before allowing the taxpayers appeal, Yuan J, stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

The test is whether … may one say that the building was renovated sufficiently enough that all or substantially all of the building has been removed or replaced: Camiré v. ...

Agence du revenu du Québec, 2025 QCCQ 1127-- summary under Subsection 45(1) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1) the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use In 1981, the taxpayers (10 individuals), acquired as co-owners two adjoining rental buildings containing a total of 82 apartments, with their respective undivided interests in such properties ranging from 2.27% to 29.2%. ...

(a)(iii)(B) includes a single individual, so it did not matter that there was only one tenant during the relevant period (para. 11); in the situation, for example, where "two individuals occupy the unit – one for a year and the other for six months –...on the basis that the plural includes the singular, the unit will qualify...by applying the test to the one individual who does occupy the unit for the whole year" (para. 12) "if there is only one occupant of a unit, in order for the unit to qualify based on the actual use test, the unit will have to be occupied by the same individual for a full period of one year (or the shorter period of time contemplated by this clause [((B)])" (para. 20) the phrase "place of residence of individuals" in s. ...

(The taxpayer testified that he spent $104,719 to install a gravel road for ¾ of the property length in order to free up a pick-up truck that had become stuck in peat.) ...

Hershfield J referred (at para. 91) to this being from the perspective of Mall Co a " quid pro quo from ICBC to forego its entitlement against Tech BC. ...

. … CIBC’s answer to question 5591 merely states that…legal advice informed its position. ...