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Dans la cause Central Mortgage & Housing Corp. v. Graham (1973 43 D.L.R. (3d) 686), le tribunal a adopté la définition donnée dans le deuxième tome de "Williston on contracts" (3ième édition, 1969). ... Avant d'essayer d'évaluer ces facteurs, il convient de revoir quelles sont les activités normales d'un réassureur, puisque l'entreprise exploitée par 24(1) Les activités principales generalement les activités suivantes: a) négociation des traités de réassurance avec les assureurs et avec d'autres réassureurs; b) vérification et comptabilisation des revenus provenant de la réassurance; c) calcul et comptabilisation des primes et des règlements avec les réassureurs secondaires; d) gestion des liquidités, des investissements et des affaires bancaires. 24(1) Pour supporter ses assertions, 19(1) s'est référé aux causes de jurisprudence Saskatchewan Farm et Barfield Enterprise's Ltd ainsi qu'à certaines positions du Ministère que l'on retrouve dans les Bulletins d'interprétation IT 396, 271R et 365R2 [[IT-396], [IT-271R], [IT-365R2]]. 24(1) Ceci nous apparait conforme a ce que l'on retrouve dans le mayeur Insurance Concepts, Presentation to the Department of National Revenue, Coopers & Lybrand, November 1983, section 5 intitulé "Reinsurace"; qui mentionne à la 2-43: Revenue Recognition Premium Written Versus Earned Premium-Earned premium is premium witten during the year plus unearned premium at the beginning of the year minus unearned premium at the end of the year. ...

That the amount received upon cancellation or extinguishment of Company B's royalty interest would fall within the ambit of subparagraph 66.2(5)(b)(v) as "... an amount in respect of a Property described in subparagraph 66(15)(c)(ii), (v) or (vii)... disposed of by the taxpayer... ... Cheshire & Burns, Modern Law of Real Property, Thirteenth Edition, states at page 852: "At common law merger results automatically from the union of two estates in the circumstances we have mentioned, and intention does not affect the result. ...

" We understand the latter version to be correct. 3. If an employee is assigned more than one company leased vehicle in a year, is the employer required to prepare a separate calculation under subsection 6(2) for each vehicle, or can the kilometres, costs and available days be totalled for the entire year for the purposes of calculating the formula based benefit? ... ") While we are not sure what the relevance is for the above two situations, it is the CCH version that is correct in its wording of this subparagraph. ...

If it is protected, does it apply only to the author or does it also cover those who may adapt or transform the software: 1. 4 Are the following distinctions {*} of significance in your internal law?----------------------------------------------------------------------- {*} For a description of some of the terms used see Annex I----------------------------------------------------------------------- 1.4.1 System or operational software and application software, 1. 4.2. ...

Early redemption ACO will have the right to redeem the Notes, in whole or in part, at a price equal to XXXXXXXXXX% of the principal amount of the Notes to be redeemed, plus accrued and unpaid interest to the date of redemption, by giving not less than XXXXXXXXXX and no more than XXXXXXXXXX days' prior notice on account of: • the termination of XXXXXXXXXX in respect of ACO's future obligations to pay the interest owing under the terms of the Initial Notes; • XXXXXXXXXX; any payment in respect of the Note becoming subject to additional amounts pursuant to a change of law, provided that no such notice of redemption shall be given earlier than XXXXXXXXXX days prior to the earliest date on which the ACO would be obliged to pay such additional amounts in relation to a payment in respect of Notes in accordance with the Indenture General redemption right The Notes shall be redeemable commencing XXXXXXXXXX and on each interest payment date thereafter, in whole or in part, at the option of ACO on not less than XXXXXXXXXX and not more than XXXXXXXXXX day's notice at a redemption price equal to XXXXXXXXXX% of the principal amount thereof, together in each case with accrued and unpaid interest to the date fixed for redemption. ...

Snider, Section Chief FROM Specialty Rulings ' Advanced Audit & Investigations DE Directorate Training Programs Section S. ...

Paragraph 6(1)(a) & (b) The Act stipulates that, except for specific exemptions (usually group plans), benefits of any kind whatever received by an individual in respect of employment are to be included in income. ... The loss on the sale is calculated as the original purchase price + capital additions- net selling price; (7) interest costs on bridge financing in the purchase of the new residence, provided that all reasonable efforts are exercised to dispose of the old residence; (8) reasonable interim living expenses at the new location while awaiting occupancy of permanent accommodation at the new location; (9) legal fees and land transfer tax for the purchase of a new residence; (10) adjustments and alterations to furniture and fixtures from the old residence to accommodate them in the new residence, including plumbing and electrical changes in the new residence for this purpose; (11) connection and installation charges for utilities, appliances and fixtures which existed at the old residence; (12) automobile licence, inspection and drivers permit fees where such items were owned at the former location; (13) the cost of revision to a will necessitated by the move; (14) moving costs of personal items and household effects including automobile, boat or trailer; (15) the cost of house hunting trips to the new location including child and pet care expenses; (16) expenses for moving an employee and household out of a remote place after the work has been completed. ...

Revenue Canada Contact Wehn taxpayers request the name of a contact at Revenue Canada you may inform them that: • Written inquiries should be forwarded to the Director-General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 • For telephone inquiries they may call the Group #23 telephone person (613) 957-2088. ...

The first technical issue to be answered is whether the words "... assignee, liquidator, administrator, executor and other like person... ... Opinion # 5-7778, dated November 1, 1985 by C. Savage). b) From the foregoing it is clear that the Department and the courts are in agreement that any person assuming duties qua liquidator can be subject to the provisions of subsection 159(2) of the ITA and by inference, subsection 14(9) of the PGRTA. ...

.' " Further support of this line of reasoning is found in the reasons for judgement by Justice Pratte of the Federal Court of Appeal in The Minister of National Revenue v. ... Ltd., [[1974] C.T.C. 63] 76 DTC 6083, where he said at page 6083; "... ...