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More information on the rationale for the deemed disposition rules is available from the Finance Canada's News Release, 98-134, Backgrounder on Taxpayer Migration and Trusts: Detailed Proposals December 23, 1998, which can be found on their website at http: // www.fin.gc.ca/finsearch/finresults_e.asp? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

That condition was also called "resolutive" because it acted to dissolve or render ineffective a contract that had already become operative. [...] ... (Emphasis mine) [...] If an amount received is, as here, in the nature of income, the fact that in the future the recipient may be under an obligation to repay it does not change the character of the receipt from income to a liability whether deferred or otherwise. ...

.; (...) 12. The Gestational Carrier... agrees to assume all risks, including risk of death that are incident to conception, pregnancy, and childbirth, including...; (...) 35. ...

C is a "specified shareholder" of the subsidiary, HOLDCO, as he owns more than 10 % of the voting shares of that corporation, pursuant to paragraph (a) of the definition of "specified shareholder" in subsection 248(1). ...

Yours truly, Olli Laurikainen CA for Director International Section II Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Paragraphs (d) and (e) of the definition of "excluded property" states:...for the purpose of the definitions "foreign affiliate" in this subsection and "direct equity percentage" in subsection (4) as they apply to this definition, where at any time a foreign affiliate of a taxpayer has an interest in a partnership, (d) the partnership shall be deemed to be a non-resident corporation having capital stock of a single class divided into 100 issued shares, and (e) the affiliate shall be deemed to own at that time that proportion of the issued shares of that class that (i) the fair market value of the affiliate's interest in the partnership at that time is of (ii) the fair market value of all interests in the partnership at that time; The term "foreign affiliate" is defined in subsection 95(1) as follows: "foreign affiliate", at any time, of a taxpayer resident in Canada means a non-resident corporation in which, at that time, (a) the taxpayer's equity percentage is not less than 1%, and (b) the total of the equity percentages in the corporation of the taxpayer and of each person related to the taxpayer (...) is not less than 10%, Forhold 2 is a foreign affiliate of Canco and a partner of LP1. ...

Pursuant to paragraph 4803(2)(a) of the Regulations, a class of shares of the capital stock of a corporation is qualified for distribution to the public if "a prospectus, registration statement or similar document has been filed with, and, where required by law, accepted for filing by, a public authority in Canada pursuant to and in accordance with the law of Canada or of any province and there has been a lawful distribution to the public of shares (...) of that class in accordance with that document". ...

Domenech, 311 U.S. 150 (1940), the Supreme Court of the U.S. held at page 163 that a treaty should generally be "... construe[d]...liberally...to give effect to the purpose which animates it". ...

In general terms, subsection 34.2(3) provides a mechanism for a corporation that becomes a member of a partnership in a year to apportion its income from the partnership for the particular period between two taxation years – the taxation year in which the particular period began and the taxation year in which it ends. ...

However, he was in exactly the same position as anyone else who, having bought a house for personal use, decided that he could not afford it – he was selling a personal use property. ...