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6 May 2004 External T.I. 2004-0057171E5- Capital Gains Deferral Unedited CRA Tags 44.1(2) 44.1(1) Principal Issues: Taxpayer enquiry on whether existing shares & proposed replacement shares will qualify for the "small business investment" capital gains deferral where the original shares and the replacement shares are shares of farming corporations. ...

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

The "Resolution of Directors" provided: " XXXXXXXXXX..... ...

Une obligation peut, dans certaines circonstances, être qualifiée de créance prescrite en vertu du paragraphe 7000(1) du Règlement de l'impôt sur le revenu ("Règlement ") et assujettie aux dispositions des paragraphes 12(4) et 12(9) ainsi que de l'alinéa 12(1)c). ...

It is also a question of fact as to whether the assistance qualifies under paragraph (a)(i) of the definition of "qualifying educational program" in subsection 118.6(1) as "an amount received [...] as a scholarship, fellowship or bursary or a prize for achievement in a field of endeavour ordinarily carried on by the student" so as not to be excluded under paragraph (a) of that definition. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

However, it does not include "... property that is principally or is used principally as (i) electronic process control or monitor equipment, (ii) electronic communications control equipment, (iii) systems software for a property referred to in subparagraph (i) or (ii), or (iv) data handling equipment unless it is ancillary to general-purpose electronic data processing equipment". ...

The Employer contributes to a defined contribution pension plan (the Pension Plan) on behalf of its employees at the yearly rate of XXXXXXXXXX % of gross earnings. ...

Subsection 73(3) of the Act states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

C-44, as amended; (h) "Corporate Act of Province A" means the XXXXXXXXXX Companies Act; (i) "CRA" means the Canada Customs and Revenue Agency, and after December 12, 2003, the Canada Revenue Agency; (j) "dollars" or "$" means Canadian dollars unless otherwise specified; (k) "Foreign Lender" means XXXXXXXXXX, a U.K. based commercial paper-funded corporation administered by Assignee; (l) "Newco" means a special-purpose corporation to be incorporated under the laws of the Province B; (m) "principal amount" has the meaning assigned by subsection 248(1); (n) "private corporation" has the meaning assigned by subsection 89(1); (o) "Province A" means the Province of XXXXXXXXXX; (p) "Province B" means the Province of XXXXXXXXXX; (q) "Province C" means the Province of XXXXXXXXXX; (r) "public corporation" has the meaning assigned by subsection 89(1); (s) "registered charity" has the meaning assigned by subsection 248(1); (t) "subsidiary wholly-owned corporation" has the meaning in subsection 248(1); (u) "TC" means Taxation Centre; (v) "Trust" means XXXXXXXXXX, as described in paragraph 3; (w) "Trustee" or "Trustee of the Trust" means XXXXXXXXXX, a corporation incorporated under the Corporate Act and a subsidiary of XXXXXXXXXX; and (x) "TSO" means Tax Services Office. ...