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These are additions to our set of 3,123 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...

Summary of May 1, 2025 Circular of Maple Leaf Foods Inc. under Spin-offs and Distributions – Butterfly spin-offs. ...

The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...

Summaries of 2021 Ruling 2019-0821121R3 under s. 55(1) – distribution and s. 96. ...

These are additions to our set of 3,215 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

Summary of 28 May 2025 IFA Roundtable, Q.5 under s. 95(1) – FAT. ...

These are additions to our set of 3,227 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

There is not considered to be such a right where the shareholders’ agreement for a corporation carrying on a franchised operation (“Franchisee”) specifies that in the event that the individual manager of Franchisee (who holds 50% of Franchisee’s commons shares) departs, the other 50% common shareholder (the Franchisor) has the mandate to find a third party to purchase the manager’s shares – or that, in such event, the manager’s shares are to be automatically redeemed by Franchisee. ...

Summaries of Joint Committee, Submission letter entitled “Technical Amendments Package of September 16, 2016" dated 15 November 2016 under s. 87(8.4), s. 90(6.1), s. 91(4.6)(b), s. 91(1.2), s. 91(1.1). s. 91(1.5), s. 212.3(2), s. 212.3(7). s. 212.3(18), s. 212.3(9)(b), s. 219.1(3)(c). s. 248(1) – derivative forward agreement, Reg. 6204(1)(b). ...

The Queen, 2017 TCC 13 under General Concepts – Agency, ETA s. 153(1), s. 232(3). ...