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However, based on two previous decisions, (Thompson Constr'n & Vancouver Tug Boat) he felt constrained as a matter of consistency to treat boiler costs as capital. ...

Si l'on utilise la méthode du coût moyen pour déterminer le coût des actions, le PBR de chaque action pour le bénéficiaire serait de 167 667 $. ...

In this case, Partner A's ACB of its partnership interest at the time of admission of Partner 8 would be $10 million for purposes of allocating income, losses or C0GPE, as the case may be, not $ nil as suggested in the hypothetical situation. ...

., XXXXXXXXXX% copyrights and XXXXXXXXXX % trademarks). In general, where a contract provides for a payment subject to tax under paragraph 212(1)(d) and for a payment that is not otherwise subject to part XIII tax under the Act, the onus is on the CRA to determine which portion of the payment is subject to tax. ...

More specifically, in technical interpretation 9203965 our Directorate stated: “... it is our view that where a corporation acquires shares of a wholly-owned subsidiary and the proceeds from the issue constitute permanent capital of the subsidiary such shares would not generally be considered to have been acquired in the ordinary course of the parent corporation's business…” In Canada v. ...

The condition set out in paragraph 3 of the eligible property definition is most relevant to this question: “‘eligible property’ means property that satisfies all of the following criteria: […] 3. ...

A barter transaction is effected when any two persons agree to a reciprocal exchange of goods or services and carry out that exchange usually without using money. […] 4. ...

XXXXXXXXXX 2021-088761 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – XXXXXXXXXX Plan (“Supplementary Plan”) XXXXXXXXXX (the “Taxpayer”) This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...

., 0.5 x (average net income /0.095 + (0.75 x net worth))- $125,000). ...

General Facts Relating to the XXXXXXXXXX Business XXXXXXXXXX The partners in the XXXXXXXXXX Partnership, together with their respective ACB’s in their partnership interests, are set forth below: Anticipated Partnership ACB as at ACB as at Interest XXXXXXXXXX $ $ XXXXXXXXXX The interest in the XXXXXXXXXX Partnership held by each of XXXXXXXXXX was held by the particular partner on February 22, 1994 and has been an excluded interest, within the meaning of subsection 40(3.15), continuously since that time. ... The outstanding common shares of XXXXXXXXXX owned by XXXXXXXXXX currently have a nominal FMV of $XXXXXXXXXX and following the proposed transfer of the shares of XXXXXXXXXX and the shares of XXXXXXXXXX (currently owned by XXXXXXXXXX) to XXXXXXXXXX, as described in Paragraph 39, will continue to have a nominal FMV of $XXXXXXXXXX Associated Corporations The XXXXXXXXXX Group owns the following share interests in the Associated Corporations: Percentage of Outstanding Estimated Shares Held ACB FMV $ $ XXXXXXXXXX FMV of the shares of the Associated Corporations, other than XXXXXXXXXX, is based on the closing share price on the relevant stock exchange on XXXXXXXXXX. ... Immediately after the share for share exchange described herein, the FMV of each XXXXXXXXXX Shareholder's shares of the capital stock of Newco1 will be equal to or approximate the amount determined by the formula (A x B) + D C as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1) of the Act. ...