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& 4. Payments of the consideration for a petroleum and natural gas lease, as described in points 3 and 4 of your memorandum, should be treated in the same way as payments of bonus consideration as described in 1 above. 5. ...

They usually take the form of either: (at a clause forming part of the rights, privileges, restrictions and conditions attaching to the shares which provides for the adjustment of the redemption price to reflect the fair market value of shares exchanged or property transferred; or (b)     a clause in a purchase and sale agreement or share exchange agreement which provides for the issuance of additional shares or cancellation of issued shares without payment such that the net number of shares will reflect the fair market value of the shares exchanged or property transferred. ...

17 December 1991 Income Tax Severed Letter 913340A F- Whether Current Expenditure or Capital Expenditure Unedited CRA Tags 20(1)(a), 18(1)(a)   913340  Dear Sirs: Re:  Replacement of Utility Poles Whether Current Expenditure or Capital Expenditure This is in reply to your letter of November 27, 1991 wherein you request our views whether utility pole replacement costs are deductible as current expenditures. 24(1) The average useful life of the poles is 25-30 years. ...

Director Reorganizations & Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

" and a building with "... rigid frame with steel channels and framework... ...

Consequently, the payments cannot be said to be for "--- the use of or the right to use---" the design. ...

(Reg'n 1400 & 1401) (i) nature of contract- life or liability (ii) reserve where life reinsured is not Canadian (iii) what are the appropriate rates for the calculation- those used the original policy or those used to calculate the reinsurance premium (iv) will the various forms of insurance have any effect of the above (stop-loss, quota share) (b) What is the appropriate reduction in reserve to the reinsured? ...

(Reg'n 1400 & 1401) (i) nature of contract- life or liability (ii) reserve where life reinsured is not Canadian (iii) what are the appropriate rates for the calculation- those used the original policy or those used to calculate the reinsurance premium (iv) will the various forms of insurance have any effect of the above (stop-loss, quota share) (b) What is the appropriate reduction in reserve to the reinsured? ...

While the information quoted by you from Hanbury & Maudsley (Modern Equity,Tenth Edition, pages 232- 233) might have been relevant for the purpose of determining certain estate duties sometime in the past, we believe it would be taken out of context in attempting to apply it to paragraph 108(1) (c) of the Income Tax Act where the words "contingent right" are specifically used. ...

Nous avons examine le problème et % notre avis il n'est pas possible de prorarer la perte en la divisant entre les divers actifs une fois l'entreprise vendue et une créance acquise si celle-ci n'est pas respectée. ...