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. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...

. … Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...

. … The limited partners did not really seem to have a choice as to whether or not they would agree to guarantee the LP loan. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

21 November 2001 External T.I. 2000-0062895 F- BOURSE D'ETUDES OU REVENU D'EMPLOI-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee – but could be non-taxable as primarily for employer’s benefit A professional services firm recruits university students and offers them a sum of money to cover the cost of their studies. ...

In this regard, the Directorate noted that, by virtue of s. 118(5), in order to claim the wholly dependent person credit in respect of the second child, no amount of child support could have been paid in respect of that child – and noted that “[i]n order for subsection 118(5) to apply, the support payments do not have to be deductible.” ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved The shareholders of a Canadian-controlled private corporation (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price in one year’s time as compared to the portion of the sale price allocated to such shares. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value The shareholders of a CCPC (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price at that time as compared to the portion of the sale price allocated to such shares. ...