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" In ascertaining the residual value, one would determine what an arm's length person would pay today in order to have the capital of the trust "x" years from now. ...

> 90%) of his duties of employment in Country P 6. Individual Y is in Country P to carry out the following activities: (a) To conclude a joint venture contract with a resident of Country P. ...

We note that the Federal Court of Appeal [[1992] 2 C.T.C. 379] (92 DTC 6473) did not deal with whether the stock option benefit was "remuneration " for purposes of the Canada-U.K. ...

Subsection 118.6(2) of the Act reads, in part, as follows: Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information "For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted an amount determined by the formula A x $60 x B (...)" ...

Subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...

., (B) all amounts each of which was included in computing the individual's income for the year and is a single payment out of or under a deferred profit sharing plan, a superannuation or pension fund or plan or a foreign retirement arrangement (I) as a consequence of the death, withdrawal from the fund, plan or arrangement or termination of employment of a person, (...)" ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

In 1980, A and B entered into a Shareholder Agreement (the "Agreement") which provided, inter alia, that Opco would acquire a term life insurance policy (no cash surrender value) in the amount of $) million on the life of each shareholder. ...

This is consistent with Justice Pinard's comments at page 6396 in the Federal Court-Trial Division case of Gaynor v The Queen [[1988] 2 C.T.C. 163] (88 DTC 6394), where he states: "... when the Income Tax Act, a Canadian statue, requires that a gain, a loss, a cost or a price be established or considered, that must be done in Canadian dollars at the relevant time, i.e. at the average exchange rate prevailing at the time such gain or loss occurs, and such cost or price is encountered. ...

As well, the "attributable to " concept thereunder will also have a significant impact. ...