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17 August 1989 Ruling 74103 F - Capital Dividend Account

Harris 957-2128 Attention: D.I. Wyse Your file: Hav 4533-3-4 File No. 7-4103 Subject: Capital Dividend Account Paragraph 89(1)(b) This is in response to your memorandum of July 6, 1989 wherein you requested our views concerning the treatment of capital gains reserves when computing a corporation's capital dividend account (CDA) under paragraph 89(1)(b) of the Income Tax Act (the "Act"). ...

9 April 1981 Income Tax Severed Letter 5-2431 F - [Article VIII of the Canada-U.S. Tax Convention]

We understand that pursuant to the corporate law of the jurisdiction in which the merger is taking place, the merger results in a dis-position by NR1 and NR2 of their assets to NR3. ...

26 September 1990 Internal T.I. EACC9617 F - Annual Review of Form T2000

EACC9617 F- Annual Review of Form T2000 Unedited CRA Tags 206.1 September 26, 1990 D.I. ...

26 November 1981 Income Tax Severed Letter

I would be pleased to visit with you in Ottawa to discuss the matter if such a dis- cussion would be of assistance. ...

10 October 1980 Income Tax Severed Letter

Jorgenson (80 ITC 6233), we will now take the view that all amounts received as damages for wrongful dis- missal are taxable (presumably as "retiring allowances") rather than being only taxable to the extent provided in subparagraph 56(1)(a)(viii) of the Act. ...

17 August 1989 Income Tax Severed Letter AC74103 - Capital Dividend Account

Harris 957-2128 Attention: D.I. Wyse Your file: Hav 4533-3-4 Subject: Capital Dividend Account File: 7-4103 Paragraph 89(1)(b) This is in response to your memorandum of July 6, 1989 wherein you requested our views concerning the treatment of capital gains reserves when computing a corporation's capital dividend account (CDA) under paragraph 89(1)(b) of the Income Tax Act (the "Act"). ...

8 June 1981 Income Tax Severed Letter 5-2537 - [810608]

It is our opinion that for the purposes only of: a) determining if a payor corporation is connected with a particular corporation at any time in a taxation year (subsection 186(4)) and, b) determining the fair market value of each type of property dis- tributed by a particular corporation to one or more other corporations in the course of a series of transactions or events the principal purpose of which was to effect a reorganization (subsection 55(3)(b)), the Department would not normally insist on a minority discount being applied When determining the fair market value of shares of a particular corporation owned by a minority shareholder. ...

Ventes d'autos Giordano Inc. v. The Queen, docket 1999-1170-GST-G

Johnny Di Girolamo, and they each held 50 percent of GAS's shares. ... Di Girolamo at a car wholesale auction. Before he started doing business with him, Mr. ... Di Girolamo and GAS were. Those who knew Mr. Cusano or Mr. Di Girolamo personally or by reputation all stated that they did not sell or remember having sold in the past any vehicle to GAS, except for one car dealer. ...

Bou Saba v. M.N.R., 2010 TCC 41

Gina Di Cesare’s testimony [35] Ms. Di Cesare worked at the intervener's clinic as a secretary and receptionist from November 1996 to June 2007. ... Di Cesare said that she had never seen the appellant clean in the evening at the clinic. [22] During the period between October 2003 and April 2004, Ms. ... Di Cesare's testimony, according to which she has never seen the appellant cleaning and has never seen meals delivered during the period at issue. ...

Gorenko v. The Queen, docket 2002-309(IT)APP

She referred to my decision in Di Modica v. Canada, [2001] T.C.J. No. 620 (Q.L.) at paragraph 16: [16] It is my view that an error by counsel can be a just and equitable reason for granting an extension of time if counsel otherwise exercised the reasonable diligence required of a lawyer. ...

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