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L'une des conditions énoncées au paragraphe 110.6(20) de la Loi est que le choix donne lieu à une augmentation du montant déductible au titre de la déduction pour gains en capital pour les autres biens de 75 000 $ de sorte que, à la suite du choix, le fils pourrait demander la totalité ou la partie inutilisée de cette déduction. ...

Seidel, CMA Technical Applications & (613) 957-2058 Valuations Division Attention: Bob Seney 2003-000063 Capital Cost Allowance This is in reply to your January 28, 2003 memorandum concerning the proper tax treatment of development costs related to XXXXXXXXXX. ...

As we have stated in the past (see, for example, documents #XXXXXXXXXX and # 2000-0047365), an IBC incorporated in Barbados would be a resident of Barbados for purposes of the Barbados Convention but for Article XXX(3) of that Convention and therefore would satisfy the test in paragraph 5907(11.2)(c) of the ITR since such an IBC is liable to tax in Barbados on its worldwide income (albeit at lower rates). ...

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

(b) Canco1 and the Lessee entered into a purchase and sale agreement ("Purchase and Sale Agreement ") which provided, inter alia, that Canco1 would sell the XXXXXXXXXX to the Lessee for $XXXXXXXXXX on XXXXXXXXXX or such later agreed date. 4. ...

The rulings are virtually identical except that in this ruling the dividend rate on the preferred shares exceeds the interest rate on the loan by XXXXXXXXXX % whereas in the prior ruling the dividend rate on the preferred shares is equal to the interest rate on the loan. ...

" In addition to the above test, the expenses must meet the additional test imposed by the preamble to subsection 20(1) of the Act which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto... ...

" In addition to the above test, the expenses must meet the additional test imposed by the preamble to subsection 20(1) of the Act which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto... ...

The original shareholdings of DC on incorporation were as follows: Shareholder Number of shares % Class of shares Stated capital W XXXXXXXXXX "A" $XXXXXXXXXX S XXXXXXXXXX "A" $XXXXXXXXXX 8. ...

M Class A Preference XXXXXXX XXXXXXX XXXXXXX Bco Common XXXXXXX XXXXXXX XXXXXXX Cco Common XXXXXXX XXXXXXX XXXXXXX The Class A Preference shares of Aco are non-voting, redeemable, retractable for an amount of $XXXXXXXXXX and entitled to non-cumulative dividends at the rate of XXXXXXXXXX % per annum of the redemption amount. ...