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Since the disposition of the property did not take place at a time when they were living separate and apart because of a breakdown in their common-law relationship … paragraph 74.5(3)(b) does not apply. ...

7 July 2005 External T.I. 2005-0122191E5 F- Erroneous Elections in Statute-barred Years-- summary under Paragraph 85(1)(c.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(c.1) no need to amend the s. 85(1) election where the agreed amount was less than the s. 85(1)(c.1) floor An individual (X) transferred all the shares of Bco to Aco in exchange for a note and common shares, electing under s. 85(1) at an amount thought to be the transferred shares’ ACB – but it later emerged that this amount was their PUC, and their ACB was higher (but still less than their FMV). ...

7 July 2005 External T.I. 2005-0122191E5 F- Erroneous Elections in Statute-barred Years-- summary under Subsection 110.6(19) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(19) no need to amend the s. 85(1) election where the agreed amount was less than the s. 85(1)(c.1) floor An individual (X) transferred all the shares of Bco to Aco in exchange for a note and common shares, electing under s. 85(1) at an amount thought to be the transferred shares’ ACB – but it later emerged that this amount was their PUC, and their ACB was higher (but still less than their FMV). ...

Regarding s. 245((2), CRA stated: [T]o the extent that there are no transactions carried out in the context of the Particular Situation with a view to circumventing those specific legislative provisions, it would probably be reasonable to consider that the Transaction would not directly or indirectly result in an abuse of the application of the provisions of the Act read as a whole …. ...

6 October 2005 External T.I. 2005-0146061E5 F- Coop de travailleurs actionnaire- montants versés-- summary under Subsection 136(2) Summary Under Tax Topics- Income Tax Act- Section 136- Subsection 136(2) workers shareholder cooperative qualified Regarding the qualification of a workers shareholder cooperative, CRA stated: As stated in F9902745 … a workers cooperative provides services to its members where it employs its members directly or indirectly. ...

Furthermore … the Plan would be intended to provide benefits to the employee upon retirement and would not be primarily intended to fund a leave of absence from the employee’s employment, thereby contravening the requirements of [Reg.] 6801(a)(i) of the Regulations. ...

27 January 2006 External T.I. 2005-0164611E5 F- Société immobilière de pension- sens de location-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside Regarding whether a pension fund real estate corporation that owns (in joint tenancy with a taxable corporation) a building that includes apartments rented to independent seniors can be considered to have limited its activities to the leasing or managing of capital property that is real property for the purposes of clause 149(1)(o.2)(ii)(A) if it provides meals, medical services and housekeeping that are billed separately, CRA stated: [T]he services provided by the Corporation … do not constitute leasing or managing capital property for the purposes of clause 149(1)(o.2)(ii)(A). ...

For example … the corporation's income from the trust would not be included in the computation of its total investment income if that income was incidental to an active business carried on by it. ...

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In these circumstances, the FMV of such work in progress of the designated professional at the end of the taxation year would be nil … [except where] it is possible, at the end of the year, to establish an amount that can reasonably be expected to be received after the end of the taxation year in respect of that work. ...