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Paragraph 21 of IC 70-6R2 [Information Circular 70-6R2] states that the Rulings Directorate will provide written opinions on the interpretation of specific provisions of the law, however, that paragraph goes on to say, "... when a requested interpretation relates to a contemplated transaction, a taxpayer should request an advance ruling rather than a opinion. ...

The appointment of a receiver does not divest the owner of his right of ownership in the assets (i.e. beneficial ownership) (In re Natural Gas Light & Appliance Co. (1918) 1 WWR 769); the appointment of a receiver has the effect of transferring possession of the debtor's assets to the receiver and permitting the receiver to deal with the assets. ...

The "cost amount" to the trust of the trust property so distributed will be determined as if the trust were a resident of Canada $7,500 (ii) Under paragraph 107 (2)(b), your client acquires the property at a cost, which is (A) the "cost amount" of the property to the trust $ 7,500 plus (B) the Adjusted cost base of your client's capital interest as at January 1, 1983 $6,600 less the "cost amount of his capital interest" (as defined in paragraph 108(1)(d)) $(7,500)_______ Excess of (A) over (B) NIL______ Cost of acquisition of property to your client $7,500______ (iii) Under paragraph 107 (2)(c), your client disposes of his capital interest for proceeds equal to (ii) above $7,500______ For the purpose of computing your client's taxable capital gain (if any) paragraph 107(1)(a) determines the Adjusted cost base of his interest to be the greater of the: Adjusted cost base of the interest (i.e. $6,600) and the "cost amount of his capital interest" (as calculated in paragraph 108(1)(d)) (i.e. $7,500). ...

Le paiement maximum des suppléments de transition est de 480 $. 6. Allocation de ré-intégration---------------------------- Un employé est éligible à cette allocation lorsque ses prestations de l'assurance-chômage sont terminées et qu'il a été incapable de se trouver un nouveau travail soit à cause de son âge, de sa santé, de son éducation ou toute autre raison valable. ...

The "cost amount" to the trust of the trust property so distributed will be determined as if the trust were a resident of Canada $7,500 (ii) Under paragraph 107 (2)(b), your client acquires the property at a cost, which is (A) the "cost amount" of the property to the trust $ 7,500 plus (B) the Adjusted cost base of your client's capital interest as at January 1, 1983 $6,600 less the "cost amount of his capital interest" (as defined in paragraph 108(1)(d)) $(7,500)_______ Excess of (A) over (B) NIL______ Cost of acquisition of property to your client $7,500______ (iii) Under paragraph 107 (2)(c), your client disposes of his capital interest for proceeds equal to (ii) above $7,500______ For the purpose of computing your client's taxable capital gain (if any) paragraph 107(1)(a) determines the Adjusted cost base of his interest to be the greater of the: Adjusted cost base of the interest (i.e. $6,600) and the "cost amount of his capital interest" (as calculated in paragraph 108(1)(d)) (i.e. $7,500). ...

Quoting from the latter judgment the Court said, "... what was said in Cival regarding the nature of the contractual relationship which is necessary to allow a taxpayer to claim deductions is equally applicable to both paragraphs 8(1)(f) and 8(1)(h). ...

Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

McCarron-McCuire LONDON DISTRICT OFFICE 17 (613) 957-2092 Attention: Brian Deacon Large Files FILE 901336 SUBJECT: 24(1) the "taxpayer" "Canadian investment income " We are writing in response to your memorandum dated June 5, 1990, regarding the method of calculating the "Canadian investment income", as defined in paragraph 129(4) (a) of the Income Tax Act (the "Act"), of the taxpayer. ...

Dans le dictionnaire Law & Commercial Dictionary de West's ce terme est défini comme étant: "In contract, the benefit or advantage which the promisor is to receive from a contract is the inducement for making it. ...

A/Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...