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Our Directorate has also confirmed in technical interpretation 9608455 that the reference in subsection 112(2.1) to a share “not acquired in the ordinary course of business” imposes a requirement to distinguish between shares acquired in functional subsidiaries and shares acquired in connection with the commercial lending activities of the shareholder. ...

Securities shall confer to their holders: 1) a right to profits made by the company whenever their distributed have [sic] been decided; 2) a right to net assets of the company at their distribution, at the dissolution of the company or in connection with the reduction of its capital (Article 53) e. ...

Rewards, which are paid in crypto-assets generally of the same type as those staked, may be earned in connection with the staking of the Staked Crypto. ...

Placer Dome Canada Limited, 2006 SCC 20) have confirmed that whether an activity constitutes hedging depends on sufficient inter-connection or integration with the underlying transaction. ...

The LLC may not have established residency in the U.S. where the only connection with the U.S. is that the U.S. is the country under whose laws it was formed and the location of the annual meeting of the board of directors. ...

Our comments As you know, XXXXXXXXXX made reference to an earlier opinion (Document E2000-004916) we issued in connection with another non-resident insurer. ...

A similar rationale was expressed in documents 2000-005649 and 2000-0011895 in connection with back to back loans where the Act provides for two income inclusions despite the fact that the inclusions might arguably be traced to the same sum of money. ...

Where all of the relevant facts pertaining to a particular situation establish that the feasibility study cannot qualify for treatment as CEE, the costs thereof would be accorded the appropriate treatment described at paragraphs 4 and 5 of Interpretation Bulletin IT-475 and question 28 of the 1986 Revenue Canada Round Table:      Normally, a feasibility study undertaken to determine whether or not a particular course of action is desirable in connection with an existing business is considered to be a current expenditure.  ...

The ordinary meaning of the words “maintain,” “modify,” or “transform”, when considered in light of their context, appear to suggest that any costs incurred in connection with these types of activities would be costs that are incurred subsequent to the acquisition of a particular property. ...

Dodd Acting Director General 957-3495 Att: Blair Chisholm Banking, Insurance and Financial Products   912991 24(1) This is in reply to your T2003 dated October 28, 1991 requesting our comments on the October 11, 1991 submission by         24(1) on behalf of the Bank          24(1)          in connection with certain of their securities transactions. ... Per the Australian High Court at p. 608:      "... and the real thing that has to be decided is what were the acts that were done in connection with the business and whether they amount to a trading which would cause the profits that accrued to be profits arising from a trade or business...      ... ...