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Pursuant to the assignment, Canco#2 was required to pay interest in respect of the loan assignment at an annual rate of XXXXXXXXXX % to USB Corp, whereas Canco#1 was obligated to pay interest at an annual rate of XXXXXXXXXX% to Canco#2 in respect of the Original Loan. 3. ...

Déterminer si le revenu provenant d'activités de construction représentent plus de 50 % du revenu total de la société est une question de faits qui nécessite l'examen de l'ensemble des faits et des activités réellement effectuées. ...

6 March 2008 Internal T.I. 2008-0269711I7- Prescribed Shares- Flow-Through Share Unedited CRA Tags 66(15) 6202.1(1)(c)(i) of the Regulations Principal Issues: Whether a share issued under a flow-through share agreement which included an indemnity clause similar to that considered in the JES Investments case would be a prescribed share Position: Yes Reasons: Conclusion of FCA in the JES Investments case March 6, 2008 Brett Evers HEADQUARTERS A/Manager Income Tax Rulings Income Tax Section (Group 2) Directorate Technical Applications & Valuations Division Ted Harris Compliance Programs Branch (613) 957-2114 Attention: David Shugar 2008-026971 Prescribed Shares for Purposes of the Flow-Through Share Rules We are writing in response to your memorandum of February 27, 2008 wherein you requested our opinion as to whether the type of indemnity clause contained in paragraph 10 of the Share Subscription and Renunciation Agreement (the "Indemnity Clause") between Deena Energy Inc. and JES Investments Ltd. described in paragraph 8 of the Federal Court of Appeal's decision in The Queen v. ...

As provided in the NCA, the purchaser paid the NCP so that for a period of XXXXXXXXXX years commencing on the closing date (the "Non-Compete Period") XXXXXXXXXX will not, among other things, ".... ...

Randy Hewlett Section Manager, Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

This description reads as follows: "XXXXXXXXXX " [Emphasis added.] ...

In your email, you referred to two internal interpretations (Documents 2002-0130827 & 2002-0162287) written by Eric Allard-Pouliot on similar fact patterns. ...

" On the basis of the Supreme Court of Canada's in Nowegijick, 83 DTC 5041, which opined that the words "in respect of" are "... of the widest possible scope," we have taken the position that a retiring allowance can encompass all types of payments arising from an employee's loss of employment. ...

Reasons: Subsection 6(6) & IT-91R4- The position in IT-91R4 that subsection 6(6) will not exclude such allowances (or employer paid expenses) from employment income where the duration of the contract is beyond two years is a general guideline. ...