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CCRA indicated that such exchange would not constitute a disposition of her interest, and that there was no transfer of her interest for purposes of s. 97(2), given that “the exchange … serves to isolate the units relating to the rights in the shares that Ms. ...

However, there were arguments that ss. 34.1(1) and (8) should be interpreted in light of s. 249.1, which contemplates the carrying on of a business at the partnership level – so that the business would cease to exist at the time the partnership ceased to exist, with the result that s. 34.1(8) would render s. 34.1(1) inapplicable. ...

However, assuming that the old partnership was not wound up for tax avoidance reasons, CCRA was prepared to instead accept arguments that ss. 34.1(1) and (8) should be interpreted in light of s. 249.1(1), which contemplates the carrying on of a business at the partnership level – so that the business would cease to exist at the time the partnership ceased to exist, with the result that s. 34.1(8) would render s. 34.1(1) inapplicable. ...

…[A]n employee who is in one of the above situations may … receive from the employer a reasonable reimbursement or allowance relating to expenses incurred in connection with transportation between the employee’s ordinary place of residence and the employee’s work location (including parking near that location) without any taxable benefit having to be included ….in computing the employee’s income from an office or employment. ...

Consequently, the condition in clause 6801(a)(iii)(A) … will be satisfied for both arrangements. ...

. … The wording of the Act does not require that the corporation employ more than 5 full-time employees throughout the year, but rather that it employ more than 5 full-time employees in the business throughout the year. ...

. … Computer software that is downloaded does not meet the characteristics of shrink-wrapped software. ...

. … [T]he expenses incurred by the taxpayer in suing his employer may not be deductible because the taxpayer did not receive compensation for the employment income lost during the suspension period. ...

20 August 2002 External T.I. 2002-0145225 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) s. 251(5)(b) not applied iteratively, where shareholders have a pro rata right to acquire another’s shares, and a contingent right to acquire those shares not taken up in the 1st round Situation 1 The shareholders' agreement between the five equal shareholders of Opco provides an obligation of each to sell its Opco shares equally to the others on the occurrence of specified events of fault such as, theft, bankruptcy a breach of any of the provisions of the agreement – but with provision for any shares not so taken up by one of the other shareholder to be divided equally for purchase by the other acquiring shareholders. ...

Consequently … the hypothecary creditor will not be able to include in the calculation of its capital dividend account the proceeds of a life insurance policy that it has received in payment of the debtor policyholder's debt because such proceeds are received only by the policyholder. ...