Search - 制暴无限杀机 下载

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. ...

In this case, Partner A's ACB of its partnership interest at the time of admission of Partner B would be $10 million for purposes of allocating income, losses or COGPE, as the case may be, not $ nil as suggested in the hypothetical situation. ...

Situation 4 (i) Opco was incorporated with all of its shares having been issued to one trust as follows: Shareholder No. and Class of Shares Subscription Price Trust 200,000 Class A preferred $200,000 Trust 1,000 common $ 1,000 The Class A preferred shares are redeemable and retractable for $1 each and bear a 7% non-cumulative dividend. ...

The word "amount" is defined in subsection 248(1) of the Act as meaning "... money, rights or things expressed in terms of the amount of money or the value in terms of money of the right or thing,... ...

The Queen, [[1988] 2 C.T.C. 24] 1988 DTC 6300, the judge held on page 6313 that "... upon careful examination of the Interpretation Bulletin produced there is clear inference that what is intended to be included in class 10(h) is equipment that is normally regarded as construction". ...