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., for example, plainly says "... it makes no real difference in substance or as to the nature of the payments whether they arise through a "reservation", strictly so called, or a covenant. ... Commissioners of Inland Revenue, "the fact that people who, after all, now all about it, choose in their agreement to refer to these annual sums *** as "royalties", is a matter not to be entirely neglected". ... Gregory & Co. 196 1 Q. B., 147; B. L. Grain Ltd. v. Ashton et al (1949) or 303). ...

Department's Position The wording of paragraph 60(j.1) refers to "an employer" and in clause 60(j.1)(ii)(a) to "... years... employed by the employer or a person related to the employer... ... Although the Act does not provide for a designation to be filed after a return of income has been filed for a particular taxation year, the Department is prepared to consider a reassessment of only the excess (deemed proceeds over safe income) if all of the following conditions are met: • the client made a reasonable attempt to calculate the safe income amount at the beginning of the series of transactions,-the transaction has been reported,- the residual amount (the excess of the proceeds over the client,s safe income) has been reported as a capital gain in the client's return of income when filed, and- the client requests in writing that the Department reassess only the excess. ...

The reference in 73(3) to "... eligible capital property in respect of a business carried on in Canada by a taxpayer... ...

You made reference to the fact that the IRS in the United States are treating such expenditures as being on account of capital, according to a published article in The Financial Post, dated November 25, 1992 which reads, in part, "... new IRS ruling prohibiting the deduction of costs associated with asbestos removal... ...

Yours truly, XXXXXXXXXX for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Consequently, its four founding shareholders currently own the common shares of Lossco as follows: Shareholder # of common shares Country of Residence Profitco XXXXXXXXXX Canada Forco1 XXXXXXXXXX United States XXXXXXXXXX ("Forco2") XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX ("Forco3") XXXXXXXXXX XXXXXXXXXX Profitco's aggregate adjusted cost base and aggregate paid-up capital attributable to its XXXXXXXXXX common shares of Lossco is $XXXXXXXXXX. 5. ...

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

Dans l'arrêt Younoman (86 DTC 6584), ces actionnaires bénéficiaient de l'usage exclusif d'une résidence d'un coût de tout près de 400 000 $. ...

Background 24(1) 24(1) Black's Law Dictionary defines payable as "a debt that is fixed and certain but the day for its payment has not arrived" and defines due as " a debt that is presently matured and enforceable". ...

Bien que M. et Mme & avaient-les mêmes droits, il n'était pas dans leur meilleur intérêt de liquider Speedway Inc., parce qu'ils n'auraient eu droit alors qu'a un avoir minime. ...