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The best indication that the test in paragraph (b) has been met is where the associated corporation has 6 or more full-time employees and it could be verified that 6 of these employees spent all their time in providing managerial services to the corporation under consideration. ...

The income derived by FA2 from payments received from FA1 in consideration for reinsuring the contracts of FA1, is deemed to be income from an active business pursuant to subparagraph 95(2)(a)(ii). ...

Our understanding of the issues for consideration would appear to relate to the time of disposition referred to in paragraph 98(1)(c) of the Act vis-a-vis the time that a partnership ceases to exist as described in paragraph 98(1)(a) of the Act and the time of distribution of property of the partnership to its members. ...

I am therefore sending a copy of our correspondence to the Honourable Bill Morneau, Minister of Finance, for his consideration. ...

In this case, the cost of the property received by the annuitant from the RRSP will be the FMV of such property (which also equals the FMV of the property given up as consideration for such property). ...

Accordingly, in general terms, a gift is a voluntary transfer of property without valuable consideration. ...

Where, at the time a share is issued, there is an accrued gain inherent in the share (for example, where the share is issued as consideration for an asset with an accrued gain which is transferred to a corporation on a tax-deferred basis under section 85), it is our view that such accrued gain will always be tainted for the purposes of subsection 55(2) of the Act. ...

We recently had further discussions with officials at the Department of Finance and after further consideration it is their view that the intention of the legislator was not to restrict the application of paragraph 810(1)(a) of the Regulations to PUBI of the non-resident insurer that is a qualified insurance corporation. ...

Any amount received by XXXXXXXXXX in consideration for such a transfer would be included in XXXXXXXXXX income and would be considered as a cost of the entitlement to receive such amounts to Newco. ...

Toutefois, dans l'examen du caractère raisonnable de ces honoraires, le temps que consacre la personne qui fournit les conseils ou les services ainsi que le genre de travail qu'elle effectue serait pris en considération. ...