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X – with the result that the Subject Shares would constitute ineligible property pursuant to s. 88(1)(c)(vi), since they would be acquired by a person (HoldcoB) who was a specified shareholder of Aco during the series and before the time at which HoldcoA last acquired control of Aco. ...

. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

Nonetheless, if the licence was attached to a specific facility and ceased to be valid when the establishment was no longer operated in that facility, it would have a time-limited duration – but that was not the case here as the licence would continue to be valid upon a change, approved by the Regional Board, in the location of the facility, so that it appeared that the licence had an open-ended duration and would be ECP. ...

In addition, the CCRA could pay Aco interest on the amount refunded at the prescribed rate … for a particular period determined under subsections 164(3) and 187(3)... ...

. … [Regarding, Art. 5(4)(e), w]hether an enterprise carries on an activity of a preparatory or auxiliary character through a server in a particular place must be determined on a case-by-case basis having regard to the business's activities as a whole. ...

However, with respect to the preferred shares of Investco owed by the Estate, while those shares also appear to satisfy the votes and value test, they do not satisfy the ownership requirement set out in (b) [of “excluded amount”] …. ...

. … In the above situation, Jcorp is a corporation controlled by the J Trust and would for the purposes of section 55, therefore, be related to the J Trust pursuant to subparagraph 55(5)(e)(iii). ...

CCRA indicated that the question of whether the payment of the “deferred salary” was of income turned on whether it was “similar to one of the items that must be included in computing a taxpayer's income for the purposes of the … Act”. ...

However … article 72 of the Decree and the absence of an employment contract or subordination relationship seem to indicate that the relationship between the creditor and the debtor of the “deferred salary” does not constitute an employer-employee relationship. ...

., a group sickness or accident insurance plan (“GSAIP”), a private health services plan (“PHSP”), or a group term life insurance policy (“GTLIP”)) allows for the provision of benefit coverage to such individuals – although a GTLIP may only provide benefit coverage to current and former (including retired) employees. ...