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There was no non-share consideration issued by UKH and the fair market value of UKO at the time of transfer was in excess of $ XXX pounds. ...

Gauvreau Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

Options This is in response to your letter of January 8, 1993, in which you ask questions concerning our response in file # 5-922384. 1. ...

Current Amendments & Regulations Division ...

Normal organization after 85(1) rollover + 84.1 application ...

Normal organization after 85(1) rollover + 84.1 application ACB $14,400 Paid-up between $1.5 M and $5 M FMV $5 M ACB $1.5 M Paid-up $14,400 FMV $5 M ...

Paragraph 6202(b) of the Regulations concerning prescribed shares for the purposes of the old flow-through share legislation ("... is a prescribed share if... a member of the related issuing group provides... any form of guarantee, security or similar indemnity with respect to the share... ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

It is your view that the XXX is not deductible pursuant to subparagraph 8(1)(i)(iv) of the Act due to the wording in subsection 8(1) of the Act which states, in part, that "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:". ...

SUBJECT: STOP-LOSS ON TRANSFER CONTROL BY GROUP SECTION: 85(5.1)] PRAIRIE PROVINCES TAX CONFERENCE May 19 & 20, 1992 DRAFT/EBAUCHE Question 1 Subsection 85(5.1) is a "stop loss" rule which applies, among other situations, where the transferee was a member of a group of persons that immediately after the disposition controlled the transferor directly or indirectly in any manner whatever (paragraph 85(5.1)(b)). ...