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“Where participating shares are exchanged for preferred shares having a FMV and a redemption value equal to the FMV of the participating shares, and because of the application of subsection 51(1) to the exchange, the ACB of the preferred shares is equal to the ACB of the exchanged participating shares, then the portion of the income earned on hand attributable to the participating shares immediately before the exchange is transferred to the preferred shares” – so that $8 million safe income of the Class A shares transferred to the 10,000 Class B shares. ...

. … [T]he CCRA considers overtime to be of an occasional nature if it is worked less than three (3) times per week. ...

(j) thereof): [A] transfer of property to a trust that is made for the sole purpose of securing the repayment of a debt or a loan within the meaning of paragraph (j) of the definition of "disposition" in subsection 248(1) nevertheless constitutes a disposition of property for the purposes of the Act, unless the transfer is also described in one of paragraphs (f), (g) or (k) of the definition of "disposition" …. ...

X – with the result that the Subject Shares would constitute ineligible property pursuant to s. 88(1)(c)(vi), since they would be acquired by a person (HoldcoB) who was a specified shareholder of Aco during the series and before the time at which HoldcoA last acquired control of Aco. ...

. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

Nonetheless, if the licence was attached to a specific facility and ceased to be valid when the establishment was no longer operated in that facility, it would have a time-limited duration – but that was not the case here as the licence would continue to be valid upon a change, approved by the Regional Board, in the location of the facility, so that it appeared that the licence had an open-ended duration and would be ECP. ...

In addition, the CCRA could pay Aco interest on the amount refunded at the prescribed rate … for a particular period determined under subsections 164(3) and 187(3)... ...

. … [Regarding, Art. 5(4)(e), w]hether an enterprise carries on an activity of a preparatory or auxiliary character through a server in a particular place must be determined on a case-by-case basis having regard to the business's activities as a whole. ...

However, with respect to the preferred shares of Investco owed by the Estate, while those shares also appear to satisfy the votes and value test, they do not satisfy the ownership requirement set out in (b) [of “excluded amount”] …. ...

. … In the above situation, Jcorp is a corporation controlled by the J Trust and would for the purposes of section 55, therefore, be related to the J Trust pursuant to subparagraph 55(5)(e)(iii). ...