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In addition, Holdco contributed a $400,000 loan to the partnership at prime + 1% to be repaid over five years by blended payments of principal and interest. ...

London & West Riding Investments Ltd. (1967) 1 All E.R. 518 (CA) and cited with approval by then Supreme Court Chief Justice Estey in Stubart Investments Ltd. v. ...

May 4, 1988 FMV of Block 1 $170,000.00 Less: ACB 1.00 Benefit $169,999.00 November 1988 FMV of Block 2 $350,000.00 Less: ACB 250 000 00 Benefit $100.000.00----------- Total Stock Option Benefit $269,999.00 =========== CAPITAL GAIN CALCULATION Proceeds- Block 1 $380,000.00 Block 2 350.000.00 $730,000.00 Less:ACB Block 1 1.00 Block 2 250,000.00 Stock Option Benefit 269.999.00 520.000.00 Total Capital Gain $210,000.00 Taxable Capital Gain- 2/3 $140,000.00 The taxpayer's accountant is of the view that his client is entitled to the stock option deduction pursuant to paragraph 110(1)(d.1) of the Act and the capital gains deduction in respect of qualified small business corporation shares pursuant to subsection 110.6(2.1) of the Act on the sale of the Block 1 shares in November of 1988. ...

Toussaint Director Bilingual Services & Resource Industries Division Rulings Directorate ...

In our view, the case of Olympia Floor & Wall Tile (Quebec) Ltd. v. ...

Situation I & II In general we agree with the comments you have made in respect of these two situations. ...

These dividend and rental payments are subject to Canadian Part XIII tax. 19(1) are concerned that we will interpret paragraphs 1 and 2 of Article $ ("Articles 4(1) and 4(2)") (a photocopy of which is attached) of the Australian Convention in such a manner that the Society will not be considered to be a resident of Australia for purposes of this Convention and will thus not be entitled to the benefits contained therein (e.g. reduced withholding rates on amounts subject to Canadian Part XIII tax). ...

You conclude that there is a problem of circularity in that, as you put it, "... under 54(g)(ii) you do not have a principal residence until you elect under 45(3) but one of the prerequisites of 45(3) is that you can only elect on a property that has become your principal residence. ...

More specifically, the reasons for our position are as follows: a) The question posed in the 1980 Round Table made reference to "... a condominium or other residential property located in the United States... held by a Canadian corporation for the occupancy of the corporation shareholder. ...

Cependant, selon vous, puisque la RAIR 26(8) ne s'applique pas à toute date donnée après la fusion aux 112 actions de corporation XY puisqu'elles n'ont pas appartenu à M.A depuis le 31 décembre 1971, vous en concluez que le PBR unitaire des 912 actions de corporation XY à une date donnée après la fusion est de 1 112.26$ (soit 1 023 500$ ÷ 912). ...