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On May 15, 1985 the Department of Finance granted a remission order in respect of the January 1, 1984 divestiture of AT & T; the remission was granted primarily because it was an involuntary spin-off resulting from a court order. ...

". Paragraph (l) of the definition of RCA in subsection 248(1) of the Act excludes an arrangement maintained primarily for non-residents in respect of services rendered outside Canada and, as a consequence thereof, foreign pension plans are usually excluded from the RCA legislation by virtue of this provision. ...

On May 15, 1985 the Department of Finance granted a remission order in respect of the January 1, 1984 spin-off of AT & T; the remission was granted primarily because it was an involuntary spin-off resulting from a court order. ...

Des terrains (mines de minéral industriel) qui ont servis dans l'entreprise mais qui ne sont plus utilisés, sont-ils des "actifs utilisés principalement dans une entreprise que la société exploite activement principalement au Canada " aux fins de la définition de "société exploitant une petite entreprise" prévue au paragraphe 248(1) de la Loi? ...

The answers in 1) & 2) apply. Reasons: 1) The land is used in the same way as the taxpayer would have used his former property during that period of time. 2) Once it is determined that the land was, before the transfer, used in the business of farming in which the taxpayer was actively engaged on a regular and continuous basis, we have to determine whether this was its primary use. ...

However, the agreement governing the sale of the customer lists and contracts will specify the allocation of the price approximately as follows: customer lists and goodwill $ 900,000 customer contracts 0 non-competition agreement 100,000 inventory cost equipment 10,000 Although the vendor corporation's sole shareholder will be a party to the non-competition agreement, he will not be entitled to receive any amount directly from the purchaser. ...

". However, travel between job sites during the course of the work day by an employee in order to carry out a contract or contracts would be "travelling in the performance of the duties of the office or employment". ...

The settlement relating to the dismissal of an employee is as follows: a) $XXXXXXXXXX- 6 month's notice (salary + commission). b) $XXXXXXXXXX- mental distress, aggravated and punitive damages. c) $XXXXXXXXXX- pre-judgement interest. d) $XXXXXXXXXX- special damages for mortgage rate differential. e) $XXXXXXXXXX- job search expenses/re-training costs. f) legal fees totalling $XXXXXXXXXX. ...

Nous sommes d'avis que, dans votre exemple, un investisseur avisé et prudent qui aurait acheté les actions ordinaires ayant un capital versé de 100 $, se serait attendu, le jour où il les a acquises, à recevoir sur ces actions un dividende pas nécessairement calculé sur le capital versé desdites actions. ...

In your letter, you have also enclosed a letter (file # 971921) dated November 13, 1997. ...