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In this case, Partner A's ACB of its partnership interest at the time of admission of Partner B would be $10 million for purposes of allocating income, losses or COGPE, as the case may be, not $ nil as suggested in the hypothetical situation. ...

Situation 4 (i) Opco was incorporated with all of its shares having been issued to one trust as follows: Shareholder No. and Class of Shares Subscription Price Trust 200,000 Class A preferred $200,000 Trust 1,000 common $ 1,000 The Class A preferred shares are redeemable and retractable for $1 each and bear a 7% non-cumulative dividend. ...

The word "amount" is defined in subsection 248(1) of the Act as meaning "... money, rights or things expressed in terms of the amount of money or the value in terms of money of the right or thing,... ...

The Queen, [[1988] 2 C.T.C. 24] 1988 DTC 6300, the judge held on page 6313 that "... upon careful examination of the Interpretation Bulletin produced there is clear inference that what is intended to be included in class 10(h) is equipment that is normally regarded as construction". ...

La cour a conclu, à la page 5065, que "... ni la Loi de I'impoôt sur le revenu ni la jurisprudence n'autorisent les tribunaux à ne pez tenir compte de l'usage direct qu'un contribuable fait d'argent emprunté... ...

The taxpayer's capital gains con- sist only of those gains which would not other- wise be included in income ("... to the extent of the amount thereof that would not... be included in computing his income... ...

For example, it seems to us that the XXX project (W/P 10-8 & 10-9) included field tests on a new product which appear to have involved XXXX which helped to optimize the design of the eventual new product. ...

Prepared by: ORIGINAL SIGNED BY Approved by: Chief Services, Public Utilities & Exempt Corporations Section Corporate Rulings Division. ...

Snider, Section Chief Specialty Rulings Advanced Audit & Investigations Directorate Training Programs Section S. ...

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