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27 October 1986 Income Tax Severed Letter 8-0041- [XXXX Stock Option Agreement- Cash in lieu of Shares] OCT 27 1986 TO Appeals Branch Appeals & Referrals Division ATTENTION H. ... Black's Law Dictionary (5th ed.) includes under the heading for "dispose of" such definitions as "... to exercise finally, in any manner, one's power of control over... to bargain away... ... " as was in fact stated in this subparagraph (with reference to "qualifying shares") prior to its most recent amendment. ...

Onge mentionne, à la page 167: "Hannan & Farnsworth in their work "The Principles of Taxation", at page 163, report the following comments of Lord Summer: If, as was held in Re Dagnall (1896) 2 Q.B. 407, a married woman continues to carry on business for the purpose of 45 & 46 Vict. c. 75, s. 1(5), as long as her trade debts remain undischarged, there.../15 000313- 15- would seem to be a presumption that a company continues to carry on business as long as it is engaged in collecting debts periodically falling due to it in the course of its former business. ... Coopers & Lybrand Limited, 80 DTC 6281 que vous avez porté à notre attention. ...

He wrote at the same place "The expressions "disposed of ", "lost" or "destroyed" were dealt with in the Australian case of Hentey Howe P.T.V. ... Cheshire & Burns, Modern Law of Real Property, Thirteenth Edition, states at page 852: "At common law merger results automatically from the union of two estates in the circumstances we have mentioned, and intention does not affect the result. ... Yours truly, Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

Replacement of Timber Limit & Cutting Rights "If an original right to cut timber is replaced by a new right, is the original right disposed of for income tax purposes? ... Regulation 700 (1)(c) "What does '... as determined by the province...' mean?" The phrase '... as determined by the province...' as used in Regulation 700(1)(c) refers to the value of logs exported by a taxpayer as determined for purposes of inclusion in income under the applicable provincial taxing statute. 5. ...

The proposed legislation will apply to “... an amount paid or the value of assistance provided by any person in respect of, in the course of or because of, an individual’s office or employment...”. ...

POSITION TAKEN: no REASONS FOR POSITION TAKEN: Ownership implies the right of alienation (the right to sell) and thus beneficial ownership of land cannot be severed if the land cannot be severed — what is left is an undivided interest interest in the whole A. ...

Le dictionnaire Le Petit Larousse illustré de 1994, définit le mot "dépense" come suit: "1 Action de dépenser de l'argent; emploi qu'on en fait. 2 Montant d'une somme à payer" Le dictionnaire The Concise Oxford définit les mots "outlay" et "spend" respectivement comme suit: "what is spent on something" "1 a pay out in making a purchase etc (...) b pay out for a particular person's benefit 2a use or consume" Par ailleurs, la question de savoir si les CVD constituent un «outlay» a été étudiée par le groupe de John Chan. ...

Le Ministère a exprimé sa position concernant le sens à accorder à l'expression "la corporation emploie dans l'entreprise tout au long de l'année (d'imposition) plus de cinq employés à plein temps" au paragraphe 14 du bulletin d'interprétation IT-73R4 du 13 février 1989: Pour le Ministère, la phrase "... la corporation emploie dans l'entreprise tout au long de l'année (d'imposition) plus de cinq employés à plein temps... ...

To this effect, we refer you to the definition of an RCA at subsection 248(1) of the Income Tax Act (the "Act") which states that an RCA means " a plan or an arrangement under which contributions... are made by an employer or former employer of a taxpayer, or by a person with whom the employer or former employer does not deal at arm's length,... ...

Guglich (613) 957-2102 Attention: XXXXXXXXXX April 28, 1993 Dear Sirs: Re: Cash & Term Deposits Used Principally in an Active Business This is in reply to your letter of December 24, 1992 in which you requested our opinion whether accumulated cash which is invested in term deposits to acquire land and a building to house the company's manufacturing operations would be considered to be "assets used principally in an active business" for purposes of the definition of qualifying small business corporation share in subsection 110.6(1) of the Income Tax Act. ...