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Snider, Section Chief Specialty Rulings Advanced Audit & Investigations Directorate Training Programs Section S. ... The expression "A = L. Cap. all classes $1,000,000" found in the middle of page 25 under the title "Common Shares" should be "A L. ...

Lors de la préparation de la déclaration d'impôt du décédé, il a été inclus dans le calcul de son revenu un gain en capital de 500 000 $ suite à une disposition réputée à la J.V.M. en vertu du paragraphe 70(5) de la Loi et l'exonération de gain en capital en vertu du paragraphe 110.6(2.1) de la Loi a été réclamée. ... Vous désirez savoir, si aux fins de l'application du paragraphe 84.1(1) de la Loi, Mme A doit utiliser le coût de 500 000 $ (aussi le P.B.R.) déterminé en vertu de l'alinéa 70(5)c) de la Loi ou si un ajustement au P.B.R. des actions doit être fait en vertu de l'alinéa 84.1(2)a.1) de la Loi. ...

Operating Income $10,000,000 less- Tax @ 48% $4,800,000- Tax Credit 2,000,000- Net Tax $2,800,000 (2,800,000) less Net Outlay for SRTC property not deducted in computing operating income- Consideration Paid $4,000,000- Cost (ss. 127.3(6)) 2,000,000- Net Outlay $2,000,000 (2,000,000) Safe Income on Hand immediately after acquisition of SRTC property $5,200,000 Gain on Disposition of SRTC property- Non Taxable Gain (1/3) $100,000- Taxable Cap. Gain 200,000- less Tax @ 48% (96,000)- Net increase in Safe Income $204,000 204,000 Safe Income on Hand immediately after disposition of SRTC property $5,404,000 ...

In addition, paragraph 67.1(2)(e), in part, reads: "... where the amount (e) is incurred by the person for food, beverages, or entertainment generally available to all individuals employed by the person at a particular place of business of the person and consumed or enjoyed by such individuals... ... On page 17 thereof, Gonthier, J. made the following comments with respect to the ordinary rules of statutory interpretation: "... there is no longer any doubt that the interpretation of tax legislation should be subject to the ordinary rules of construction. ... While not restricted to a Christmas party, it could provide an exception for costs relating to another function that is "... generally available to all individuals employed by the person at a particular place of business of the person... ...

Thomas Nelson & Sons Ltd., (1938), 22 T.C. 175 (Ct. of Session). While the Court in Lord Howard de Walden v. ... & J. Black, endorsed by them and paid into the Appellant's account. ... Peter Dixon & Son, Ltd. (1943), 25 T.C. 353 (C.A.)]. In any event, as discussed earlier, XXX does not carry on a financing business. ...

27 October 1986 Income Tax Severed Letter 8-0041- [XXXX Stock Option Agreement- Cash in lieu of Shares] OCT 27 1986 TO Appeals Branch Appeals & Referrals Division ATTENTION H. ... Black's Law Dictionary (5th ed.) includes under the heading for "dispose of" such definitions as "... to exercise finally, in any manner, one's power of control over... to bargain away... ... " as was in fact stated in this subparagraph (with reference to "qualifying shares") prior to its most recent amendment. ...

Onge mentionne, à la page 167: "Hannan & Farnsworth in their work "The Principles of Taxation", at page 163, report the following comments of Lord Summer: If, as was held in Re Dagnall (1896) 2 Q.B. 407, a married woman continues to carry on business for the purpose of 45 & 46 Vict. c. 75, s. 1(5), as long as her trade debts remain undischarged, there.../15 000313- 15- would seem to be a presumption that a company continues to carry on business as long as it is engaged in collecting debts periodically falling due to it in the course of its former business. ... Coopers & Lybrand Limited, 80 DTC 6281 que vous avez porté à notre attention. ...

He wrote at the same place "The expressions "disposed of ", "lost" or "destroyed" were dealt with in the Australian case of Hentey Howe P.T.V. ... Cheshire & Burns, Modern Law of Real Property, Thirteenth Edition, states at page 852: "At common law merger results automatically from the union of two estates in the circumstances we have mentioned, and intention does not affect the result. ... Yours truly, Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate ...

The proposed legislation will apply to “... an amount paid or the value of assistance provided by any person in respect of, in the course of or because of, an individual’s office or employment...”. ...

POSITION TAKEN: no REASONS FOR POSITION TAKEN: Ownership implies the right of alienation (the right to sell) and thus beneficial ownership of land cannot be severed if the land cannot be severed — what is left is an undivided interest interest in the whole A. ...