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Fisher states "... the basic intention of Parliament must have been to permit a deduction where an individual... necessarily required the services of a full-time attendant by reason of the illness, infirmity or affliction of such individual". ...

According to the Canadian Almanac & Directory 1988 Clark Pitman Ltd 24(1) is, not an urban municipality and as a result licenses would be required under the TTA for any transportation service being run out of the community. ...

Original signed by Chief Merchandising, Manufacturing & Construction Corporate Rulings Division Corporate Rulings Directorate Legislation Branch s.10 Research File CR2220 Inventory ...

In addition, Holdco contributed a $400,000 loan to the partnership at prime + 1% to be repaid over five years by blended payments of principal and interest. ...

London & West Riding Investments Ltd. (1967) 1 All E.R. 518 (CA) and cited with approval by then Supreme Court Chief Justice Estey in Stubart Investments Ltd. v. ...

May 4, 1988 FMV of Block 1 $170,000.00 Less: ACB 1.00 Benefit $169,999.00 November 1988 FMV of Block 2 $350,000.00 Less: ACB 250 000 00 Benefit $100.000.00----------- Total Stock Option Benefit $269,999.00 =========== CAPITAL GAIN CALCULATION Proceeds- Block 1 $380,000.00 Block 2 350.000.00 $730,000.00 Less:ACB Block 1 1.00 Block 2 250,000.00 Stock Option Benefit 269.999.00 520.000.00 Total Capital Gain $210,000.00 Taxable Capital Gain- 2/3 $140,000.00 The taxpayer's accountant is of the view that his client is entitled to the stock option deduction pursuant to paragraph 110(1)(d.1) of the Act and the capital gains deduction in respect of qualified small business corporation shares pursuant to subsection 110.6(2.1) of the Act on the sale of the Block 1 shares in November of 1988. ...

Toussaint Director Bilingual Services & Resource Industries Division Rulings Directorate ...

In our view, the case of Olympia Floor & Wall Tile (Quebec) Ltd. v. ...

Situation I & II In general we agree with the comments you have made in respect of these two situations. ...

These dividend and rental payments are subject to Canadian Part XIII tax. 19(1) are concerned that we will interpret paragraphs 1 and 2 of Article $ ("Articles 4(1) and 4(2)") (a photocopy of which is attached) of the Australian Convention in such a manner that the Society will not be considered to be a resident of Australia for purposes of this Convention and will thus not be entitled to the benefits contained therein (e.g. reduced withholding rates on amounts subject to Canadian Part XIII tax). ...