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XXXXXXXXXX will realize a foreign exchange loss of approximately $XXXXXXXXXX on the assumption of Loan 1, as a result of the fluctuation in the exchange rate of US $ on the day of the assumption compared to the rate when the loan was made. 28. ...

XXXXXXXXXX will sell, at fair market value, to Subco XXXXXXXXXX % of its cash and near-cash property and investment property. ...

The Exercise Price will be approximately XXXXXXXXXX % of the market price (on the XXXXXXXXXX Stock Exchange) of the CCo Stock (XXXXXXXXXX) on the date on which the offering of the Units is priced. ...

April 24, 1998 Policy & Procedures Marie-Marthe Gagnon International Audit Division (613) 957-8953 International Tax Directorate Attention: René Fleming, Interim Manager 7-973015 Section 122.3- Overseas Employment Tax Credit This is in reply to your letter of November 12, 1997, requesting our comments concerning the application of the Overseas Employment Tax Credit in a particular factual situation. ...

On the incorporation of XXXXXXXXXX, 1 common share will be issued to XXXXXXXXXX for aggregate consideration of $ XXXXXXXXXX. 20. ...

Position TAKEN: 1) No 2) No 3) Yes 4) No Reasons FOR POSITION TAKEN: 1) Consistent with the position in IT-385R2 and in previous rulings (973094, 972779 & 970604) 2) The variation is not significant enough to consider that there has been a disposition (972779). 3) The Distribution pursuant to subsection 107(2) is consistent with Finance's comments contained in the Technical Notes regarding the 21-year rule. 4) This issue was referred to the GAAR Committee and it was recommended that GAAR not apply to the proposed transactions. ...

Subsection 227(8) of the Act states “... every person who in a calendar year has failed to deduct or withhold any amount as required by subsection 153(1) or section 215 is liable to a penalty of (a) 10% of the amount that should have been deducted or withheld; or (b) where at the time of the failure a penalty under this subsection was payable by the person in respect of an amount that should have been deducted or withheld during the year and the failure was made knowingly or under circumstances amounting to gross negligence, 20% of that amount. 6. ...

L'une des conditions énoncées au paragraphe 110.6(20) de la Loi est que le choix donne lieu à une augmentation du montant déductible au titre de la déduction pour gains en capital pour les autres biens de 75 000 $ de sorte que, à la suite du choix, le fils pourrait demander la totalité ou la partie inutilisée de cette déduction. ...

Seidel, CMA Technical Applications & (613) 957-2058 Valuations Division Attention: Bob Seney 2003-000063 Capital Cost Allowance This is in reply to your January 28, 2003 memorandum concerning the proper tax treatment of development costs related to XXXXXXXXXX. ...

As we have stated in the past (see, for example, documents #XXXXXXXXXX and # 2000-0047365), an IBC incorporated in Barbados would be a resident of Barbados for purposes of the Barbados Convention but for Article XXX(3) of that Convention and therefore would satisfy the test in paragraph 5907(11.2)(c) of the ITR since such an IBC is liable to tax in Barbados on its worldwide income (albeit at lower rates). ...