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Subject: CCPC SHARES PURCHASED UNDER STOCK OPTION & S. 85 ROLL Section(s): 7(1.1), 85(1)] 913135 L. ...

Roynat [[1981] C.T.C. 93] (81 DTC 5072) and in the McLaw's case mentioned above where at page 6153, Hall J. makes the following comment: “the interest paid by the appellant..... ” We trust that the above satisfactorily explains the Department's position. ...

We suggest that the end of the last sentence in paragraph 15 be modified to read as follows: ", Mr. ...

& 2. If the company gives an employee a notice of termination, for example of one (1) month, but tells the employee if you leave immediately we will pay you for that month in addition to the amount in respect of the termination of employment, will that additional amount constitute a "retiring allowance"? ...

Accordingly, an individual must have "... received a loan or otherwise incurred a debt by virtue of the office or employment... ...

Subsection 55(2) of the Act will apply if the parent pays a dividend that reduces the inherent gain in the shares of the parent "... attributable to anything other than income earned or realized by any corporation after 1971... ...

The Queen [[1986] 1 C.T.C. 219] (86 DTC 6039 and [[1988] 1 C.T.C. 60] 88 DTC 6053) the Federal Court, Trial Decision stated on page 6053 (86 DTC) that "... the predecessor of 245(2) was interpreted as in effect adding a new sub-clause to each of Parts I, III and IV of the then Act as appropriate". ...

Cummings v The Queen, [[1981] C.T.C. 285] [1981] CTC 285 (FCA): [...] the fact of the acceptability in accounting practice of dealing with a particular item in a particular manner, cannot, by itself make that practice a proper deduction for income tax purposes. ...

SUBJECT: CHANGE IN CONTROL CARRYOVER OF TAX POOLS SECTION: 111(4), 111(5), 111(5.1)] Minister/DM's Office Y.S. 92-3646T Central Records Author Section Chief D.O. (?) ...

SUBJECT: PROCEEDS OF DISPOSITION SECTION: 20(1)(c)] Prairie Provinces Tax Conference May 19 & 20, 1992 DRAFT/EBAUCHE Question 16 On a sale of shares there is an effective date and a subsequent legal closing date. ...