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Thomas Nelson & Sons Ltd., (1938), 22 T.C. 175 (Ct. of Session). While the Court in Lord Howard de Walden v. ... & J. Black, endorsed by them and paid into the Appellant's account. ... Peter Dixon & Son, Ltd. (1943), 25 T.C. 353 (C.A.)]. In any event, as discussed earlier XXXX does not carry on a financing business. ...

In deciding the Burgess case, he stated at the same place that "... the legal expenses are in the nature of a capital expenditure, by bringing the right into being, rather than in the nature of a revenue expenditure to enforce payment of income from a right in being". ... Yours truly, Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

At that time, XXXXXXXXXX comprised more than XXXXXXXXXX % by value of the Canadian Group. ... Estimates made by senior management of the Canadian Group indicate that more than XXXXXXXXXX % of the fair market value of the shares of XXXXXXXXXX may be attributable to the XXXXXXXXXX Properties of XXXXXXXXXX Additional Information 11. ...

For purposes of determining the amount of any deemed dividend under the provisions of subsection 84(2) of the Act, is this liability deducted in the determination of “... the amount or value of the funds or property distributed or appropriated...”? ... DEPARTMENT'S POSITION Subject to certain adjustments set out therein, paragraph 89(1)(c) of the Act provides that the “paid-up capital” in respect of a class of shares of the capital stock of a corporation is “... an amount equal to the paid-up capital in respect of the class of shares at the particular time, computed without reference to the provisions of this Act...” ...

. • In year 1, Division A (employee contributions) pays out XXX in claims while earning XXX in interest and spending XXX on administrative expenses. • In the same year, Division B (employer contributions) pays out XXX in claims while earning XXX in interest and spending XXX in administrative expenses. ...

The issue that must be decided in a particular case is therefore whether the taxpayer's activities are, in fact, with respect to "prospecting, exploring or drilling " or with respect to basic research, applied research or development of new or improved materials, devices, products or processes. ... Chief, Mines, Oil & Forest Industries Specialty Corporation Rulings Division Corporate Rulings Directorate Legislation Branch c.c. ...

This aspect was emphasized in the second paragraph of your News Release of October 26, 1983 and of particular significance is the fact that ".. each situation will be of necessity judged on its own merits". (3) In each of the scenarios, the distributor is granted the rights to monitor the production process, to act as an observer or as a consultant, without any right of veto. ... As discussed, we were alarmed with the impression given in the October 27 Globe & Mail article by Dan Westell entitled: "Fox offers new tax changes to lure broadcast investment". ...

XXXX argumentation could be summarized as follows:- In the interpretation of statutes, there is a presumption against retrospective operation "unless by express words or necessary implication it appears that such was the intention of the legislature" (Driedger, Elmer A: The Construction of Statutes, 1983, Butterworth & Co. ... London, Sweet & Maxwell. 1969, at page 33. 3. Our reading of the authorities does not lead us to the same conclusion as XXXX with request to "retrospectivity" and "retroactivity". ...

2 August 1985 Income Tax Severed Letter 7-4095- [N/A] FOREIGN & SMALL BUSINESS SECTION D. ... Since this will result in the conversion of taxable dividends to capital gains in to a provision such as subsection 84(1) of the Act to remedy the situtation, we have brought this to the attention of our Current Amendments & Regulations Division. ...

Page 4.2, paragraph 4, line 2, we suggest that the words "of a particular class to which the takeover bid relates" be added after the words " of the holders of the shares" and that the word "affected" be deleted from this sentence. ... Page 4.2, paragraph 5, line 2, we suggest that the words " of the shareholders of each amalgamating corporation" be added after the words "a special resolution". ...