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On page 5223 of the case, the court acknowledged that "... in the case of the purchase of a business as a going concern,... the expenditure (if it is not clearly for the purchase of stock in trade) is always a capital expenditure... ... These cases include Ross & Day, [[1976] C.T.C. 707] 76 DTC 6433 (FCA), Transport Direct Systems, [[1984] C.T.C. 2845] 84 DTC 1773 (TCC), Burnco Industries Ltd., [[1984] C.T.C. 337] 84 DTC 6348 (FCA), Harlequin Enterprises Limited, [[1977] C.T.C. 208] 77 DTC 5164 (FCA), and Amesbury Distributors Limited, [[1984] C.T.C. 667] 85 DTC 5076 (FCTD). ...

Il n'y a pas de limite quant à la durée d'une position à découvert tant que le courtier du vendeur peut emprunter une quantité équivalente de titres vendus à découvert et que le vendeur maintient une couverture suffisante dans son compte à découvert. [...] 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. [...] 5. ...

14 June 1990 Income Tax Severed Letter 14 June 1990 TO Appeals Branch Appeals & Referrals Division FROM Scientific Research Audit Applications Audit Programs Directorate R.P.Laramy 952-0605 Attention: J.E.Nordin SUBJECT: Current Expenditures of Sole-Purpose Scientific Research and Experimental Development (SR&ED) Corporations We are writing in reply to your memorandum which dealt with expenditures incurred by sole-purpose SR&ED companies. ... Advertising and selling expenses which constitute general administration and management expenses- Regulation 2902 (a) (i) (D) & (E) expenditures In our view, advertising and selling expenses that fall into this category would relate specifically to promoting the business of performing SR&ED, rather than promoting the product or process that is developed as a result of the SR&ED. ...

Il n'y a pas de limite quant à la durée d'une position découvert tant que le courtier du vendeur peut emprunter une quantité équivalente de titres vendus à découvert et que le vendeur maintient une couverture suffisante dans son compte découvert. {...) 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. {...} 5. ...

P-Note 2 will be due within three years of the closing of the Proposed Transactions; “PUC” means “paid-up capital” as that term is defined in subsection 89(1) of the Act; “Proposed Transactions” means the transactions described in Paragraphs 45 to 54; “related person”, or persons related to each other, has the meaning assigned by subsection 251(2); “Safe Income” means, with respect to a taxable dividend described in paragraph 55(2.1)(a) that is received by a dividend recipient from a dividend payer, the amount of income earned or realized by a corporation — after 1971 and before the safe income determination time with respect to the transaction, event or series of transactions or events — that could reasonably be considered to contribute to the capital gain that would have been realized upon a disposition at FMV, made immediately before the dividend, of the share on which the dividend was received; “Sequential Butterflies” means the First Butterfly, the Second Butterfly and the Third Butterfly, referred to collectively; “TCC” means “taxable Canadian corporation” and has the meaning assigned by subsection 89(1); “Tco” means XXXXXXXXXX, a public corporation created under the BCA3, the shares of which are publicly traded; “Xco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 163 of the Initial Ruling; “Yco” means XXXXXXXXXX, a corporation incorporated under the BCA1, as described in Paragraph 170 of the Initial Ruling; “Yco Management Employee 1” is an individual resident in Canada for the purposes of the Act who owns shares in a holding corporation owning shares in Yco and who also owns shares directly in Yco; “Yco Management Employee 2” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 3” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 4” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; “Yco Management Employee 5” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco; and “Yco Management Employee 6” means an employee of Yco who is an individual resident in Canada for the purposes of the Act and who is not related to Yco. ...

Specifically, as noted in paragraphs 4 and 5 of Interpretation Bulletin IT-273R2, Government Assistance – General Comments, (footnote 8) generally, when a taxpayer receives or is entitled to receive government assistance for the acquisition of depreciable property (before the disposition of the property), subsection 13(7.1) of the Act applies to reduce the capital cost of the property by the amount of the assistance. ... Yours truly, Pamela Burnley CPA, CA Manager Business and Capital Transactions Section Business and Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 As stated in question 9 in the Frequently Asked Questions section of the BC Housing Secondary Suite Incentive Program website, the minimum loan under the Program is $10,000, which means that construction costs of $20,000 or more need to be incurred by a Homeowner to participate in the Program. 2 As you indicated, the RALs are the median rent levels for each area and unit size as determined by the Canada Mortgage & Housing Corporation in their annual rental market survey. 3 In a situation where the SSIP Loan is not forgiven within the first 5 years of the Program, BC Housing may, at their sole discretion, extend the mortgage term to a maximum of 10 years from commencement (the opportunity for forgiveness will continue) of the BC SSIP. 4 The Secondary Suite must be newly constructed under municipal building permits received on or after April 1, 2023. 5 Based on question 12 in the Frequently Asked Questions section of the BC Housing Secondary Suite Incentive Program website. 6 See also Line 9946 of the T4036 Rental Income guide for discussion of situations where property is regularly rented below fair market value, under the heading “Renting below fair market value” 7 https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/t4036/rental-income.html 8 https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/it273r2.html 9 https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-1-individuals/folio-3-family-unit-issues/income-tax-folio-s1-f3-c2-principal-reside... 10 Refer to paragraph 2.13 of the PR Folio for explanation of the phrase family unit. 11 A possible exception to this might be where a Homeowner rents the Secondary Suite to their former spouse or former common-law partner who is both a Qualifying Tenant under the BC SSIP and a family member that can meet the “ordinarily inhabited” requirement for purposes of the principal residence definition in section 54 of the Act. ...

Provided that, as part of the series of transactions or events that includes the proposed transactions, there is not: \* MERGEFORMAT \* MERGEFORMAT (i) a disposition of property in the circumstances described in subparagraph 55(3.1)(b)(i); (ii) an acquisition of control in the circumstances described in subparagraph 55(3.1)(b)(ii); or (iii) an acquisition of property in the circumstances described in paragraph 55(3.1)(c) or (d); which has not been described herein, then by virtue of paragraph 55(3)(b), subsection 55(2) will not apply to the taxable dividends referred to in the rulings given in I and K above and, for greater certainty, subsection 55(3.1) will not apply to deny the exemption under paragraph 55(3)(b). ...

The aggregate FMV, immediately before the Distribution, of the Foreign Spinco Common Shares owned by Foreign Services will be equal to or approximate the amount determined by the formula: (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1) on the assumption that Foreign Services is the participant, DC is the distributing corporation and Foreign Spinco is the acquiror. ...

The aggregate FMV, immediately before the transfer of property by Canadian DC to Canadian TC described in Paragraph 120, of the common shares of the capital stock of New DC owned by Forco 23 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 23 is the participant, Canadian DC is the distributing corporation and New DC is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 117. ... The aggregate FMV, immediately before the transfer of property by New DC to New TC described in Paragraph 135, of the shares of New DC owned by Forco 14 will be equal to or approximate the amount determined by the formula, on the assumption that Forco 14 is the participant, New DC is the distributing corporation and New Global Holdco is the acquiror, (A × B/C) + D as found in subparagraph (b)(iii) of the definition of “permitted exchange” in subsection 55(1). 135. ...

As minor & unborn children were involved the value of the contingent capital interests were determined & set aside in a separate trust. ...