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The Band Council only owned XXXXXXXXXX % of the shares. De facto control of the corporation was not with a person exempt from tax under section 149. ...

Department of Fisheries & Oceans Allocation Transfer Program Questions and Answers For Canada Customs and Revenue Agency Client Services The Department of Fisheries and Oceans ("DFO") is responsible for issuing fishing licences which include commercial fishing licences to the public. ...

Robert Parsons stated: “ if the producer should choose to close out the forward sales contract earlier than it was required to do, by purchasing an equivalent amount of product, this action does not alter the characterization of the gain or loss on the forward sales contract as a hedging transaction. ...

., XXXXXXXXXX% copyrights and XXXXXXXXXX % trademarks). In general, where a contract provides for a payment subject to tax under paragraph 212(1)(d) and for a payment that is not otherwise subject to part XIII tax under the Act, the onus is on the CRA to determine which portion of the payment is subject to tax. ...

More specifically, in technical interpretation 9203965 our Directorate stated: “... it is our view that where a corporation acquires shares of a wholly-owned subsidiary and the proceeds from the issue constitute permanent capital of the subsidiary such shares would not generally be considered to have been acquired in the ordinary course of the parent corporation's business…” In Canada v. ...

The condition set out in paragraph 3 of the eligible property definition is most relevant to this question: “‘eligible property’ means property that satisfies all of the following criteria: […] 3. ...

A barter transaction is effected when any two persons agree to a reciprocal exchange of goods or services and carry out that exchange usually without using money. […] 4. ...

". In my view, this provision is to be interpreted as it would be understood in the mining industry, for which Parliament included Canadian exploration expense as defined in s/p (iii.1) as a benefit to attract investment in resource production. ...

Payroll Services Company, for and on behalf of Company One, shall charge back to Company One's customers the total cost of labour above + XXXXXXXXXX% premium for employee management, unless otherwise agreed to in writing. ...

Frost and as evidenced by Standard & Poor's credit watch discussed above. ...