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., exclusive possession of the property was not given), CRA cited Will-Kare for the proposition that " the concepts of a sale or a lease have settled legal definitions. ...

21 September 2011 External T.I. 2010-0375361E5 F- Liquidation d'une coopérative agricole-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) s. 84(2) applied to winding-up of cooperative Respecting the treatment of the winding up of an agricultural cooperative within the meaning of s. 135.1(1) pursuant to which the cooperative distributes the balance of its assets to its members (with such distribution not satisfying the definition of " allocation in proportion to patronage” in s. 135(4). ...

Regarding the consequences of disposing of the bond between the November 1 due dates, CCRA stated: IT-410R [para. 3] … states that interest accrued between two due dates for the payment of interest on the obligation will be calculated at the rate stipulated in the terms of the obligation. ...

. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...

B … would be deemed to be nil by virtue of paragraph 40(3.6)(a). Consequently, no amount of the Denied Loss could be attributed to Ms. A under subsection 74.2(1) …. By virtue of paragraph 40(3.6)(b), the amount of the Denied Loss … could, however, be added to … the ACB, to Mr. B, of each of the common shares of … Opco that is owned by him immediately following the disposition of such preferred shares of the capital stock of Opco. ...

X commences to use his condominium exclusively for personal purposes, would he be able to use the s. 45(3) election to defer the taxation of the capital gain until the actual sale of his property if he designates the condominium as his principal residence – and would the answer change if Mr. ... However … where Mr. X … used the property entirely for the purpose of earning income and … at a later time began to use it exclusively for personal purposes … the taxpayer would be able to rely on the subsection 45(3) election if subsection 45(4) does not apply and the condominium becomes the taxpayer's "principal residence" …. ...

CRA responded: [T]he conditions in the preamble to subsection 249.1(4) must … be … satisfied in each of the fiscal periods following that first fiscal period of the business in order for subsection 249.1(4) to continue to apply …. Among the conditions … [is that] each member of the partnership is an individual and the partnership is not a member of another partnership. … [W]hen Partnership A became a member of Partnership B, the two partnerships no longer satisfied the conditions of subsection 249.1(4) for the current fiscal period …. ...

CCRA stated: [T]he conversion or exchange rights attached to the newly acquired Class A shares … and permitting the exchange of such shares for Class B shares … would technically constitute a "right to acquire" the substituted property …. These conversion or exchange rights would therefore be deemed to be property identical to the Class B shares … previously disposed of by the Taxpayer. Consequently, the loss incurred by the Taxpayer and resulting from the disposition of the Class B shares … would be a "superficial loss" …. ...

Canadian Acme Screw & Gear, Ltd. [1971] S.C.R. 628. ...

Canadian Western and Natural Gas, Light, Heat & Power Co. in concluding that the word "similar" meant "of the same general nature or character", and went on to indicate that in the past it had regarded the following properties or services to be similar: (a) system software and applications software; (b) trucking of sand and gravel, and trucking of poultry and lumber; (c) mining and sale of metallurgical coal, and mining and sale of other minerals; (d) operating a hotel which includes a restaurant and lounge, and operating a restaurant and lounge; (e) operating a hotel or motel with no restaurant, operating a restaurant, and operating a hotel or motel with a beverage room but no separate restaurant, and operating a hotel with a restaurant; (f) operating a prime rib restaurant and operating a steak restaurant even where the latter is operated in conjunction with a hotel; (g) the sale of fast-food chicken and the sale of fast-food fish; (h) staging musical concerts in a stadium, and staging professional football; (i) security equipment, and electro-magnetic labels developed for use in libraries, hospitals and retail establishments; and (j) the manufacture of parts and major components for aircraft, and the design, manufacture and sale of aircraft. ...