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The subsidiary is actually paying financing fees to the parent in the amount reimbursed and a strong connection would exist between the fees that the subsidiary is paying to the parent and the subsidiary issuing shares or debt]. ...

They were losses incurred in connection with a capital venture.... I think it is clear that an expenditure incurred for the purpose of enabling a taxpayer to decide whether a capital asset should be acquired is an outlay or payment on account of capital............ [49] Consequently, the abandonment of the 1994 project to open a store in co-operation with Groupe Lespérance and the 1998 projects to open stores in co-operation with Revy and perhaps with Loyola does not change the nature of the amounts that would otherwise have been capital outlays.... ...

As emphasized by the preamble to subsection 20(1) of the Act, there must be a clear connection between the amount to be deducted and the source of the borrowing. ...

In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for purposes that would have qualified for interest deductibility had the capital been borrowed money (eligible purposes). ...

In connection with these requests we reconsidered our previous opinion, our response to question 33 of the Revenue Canada Round Table at the 1988 Canadian Tax Conference, and the relevant jurisprudence and literature. ...

This position does not apply to borrowing that arises in connection with a cashless exercise of warrants or a margin account. ...

Moore for Director International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Defined as any agreement that may be entered into from time to time that caps the amount payable to the MRPS shareholder in respect of Dividend 2. 2 Defined as any agreement that may be entered into from time to time that documents a commitment to subscribe for shares in Holdings in connection with the redemption of the MRPS. 3 Defined as the earnings accrued or received or any gain realized by Finance as determined according to XXXXXXXXXX in relation to the XXXXXXXXXX financial assets acquired or to be acquired by Finance and financed directly with the proceeds resulting from the issuance of the MRPS and/or any other XXXXXXXXXX financial assets replacing from time to time such assets or purchased or financed with the Income and other proceeds arising out of such financial assets or of a disposal of all or part of such financial assets. ...

Where the bursary is received in connection with the individual's enrolment in an educational program eligible for the education tax credit, the full amount will be exempt. ...

The scope of the profitable activities of the Association and the lack of connection between these activities and the not-for-profit objectives of the Association indicate that the Association has a profit purpose as well as not-for-profit purposes. ...

It generally provides the following (capitalized words refer to defined terms in the agreement): a. that CanGP and CanLP agreed to form and CanGP did form, by filing a certificate with the Secretary of State of Delaware, an LLLP under the DRULPA XXXXXXXXXX; b. that the LLLP may engage in any and all lawful business activities and do all things generally necessary in connection with or incidental to its own activities XXXXXXXXXX; c. the details of the Partners’ Capital Contributions and the Partnership Percentage XXXXXXXXXX; d. the rules to maintain each Partner’s Capital Account XXXXXXXXXX; e. the rules for the allocation of Profits or Losses to Partners XXXXXXXXXX; f. the timing and amount of Distributions, generally determined by CanGP, of Cash Flow From Operations, and of Sale or Refinancing Proceeds, which involve CanGP’s discretion to set aside sufficient Reserves XXXXXXXXXX; g. that CanGP has the exclusive management and control of the business of the LLLP, shall make all decisions regarding the management and affairs of the LLLP, and has extended rights and powers to do so XXXXXXXXXX; h. the setting up of a Board of Managers that shall provide overall guidance to CanGP in the management and affairs of the business and that shall provide direction to CanGP in carrying out the day-to-day operations of the LLLP XXXXXXXXXX; i. that CanLP will have no right or power to take part in the management or control of the LLLP or its business and affairs or to act for or bind the LLLP in any way, except where CanLP may vote on the matters that expressly require its approval under the Agreement XXXXXXXXXX; j. the obligations and duties of CanGP, including CanGP’s duty of loyalty to the LLLP and to CanLP as specifically limited, and the requirement that CanGP shall use its best efforts to carry out the purposes of the LLLP for the benefit of all the Partners XXXXXXXXXX; k. limitation of liability for CanGP and CanLP in respect of the obligations of the LLLP XXXXXXXXXX; l. for the termination of status of CanGP XXXXXXXXXX; m. that CanLP may, among other things, transfer, assign, pledge, mortgage or donate all or any part of its Partnership Interest with the prior written consent of CanGP XXXXXXXXXX; and n. the Liquidating Events, which don’t include a predetermined date XXXXXXXXXX. 6. ...