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The various connections between the Reserve and the Appellants’ income from fishing are indisputably bona fide and not motivated by tax avoidance considerations. ...

Thomson (613) 670-9002 2012-045767 Re: Article 15 and Treaty Triangulation Dear XXXXXXXXXX: This is in response to your query of July 2012 in which you ask for our comments on some additional considerations regarding document 2009-031995, which we issued on January 25, 2010. ...

Si le contribuable fait partie d’une société de personnes, le paragraphe 96(3) doit de plus, être pris en considération. ...

B and there are residual assets) for no consideration. They will make no direction regarding who is entitled to receive the benefit from disclaiming their interest. 12. ...

The Club’s board believed the offer deserved consideration since it offered an attractive solution to save the Club the considerable expense of renovating its aging facilities and would provide it with the additional capital surplus to maintain a XXXXXXXXXX in the future. 11. ...

X wants to transfer the policy to its wholly-owned corporation for no consideration. ...

While we don't have any formal guidelines on how to make the determination of whether or not a scramble parking situation exists, some possible considerations in making this determination include: How many employees actually use the parking at any given time, taking into account whether there is shift work, and/or that on a given day a number of employees will be absent because they are not working in the office or they are off due to vacation days, sick days etc. ...

On XXXXXXXXXX, Limited Partnership A and Amalco will transfer the Limited Partnership A business, the LPA Sub1A business, and the LPA Sub2A business, respectively, to Limited Partnership B for fair market value consideration including limited partnership units of Limited Partnership B. ...

Moreover, since the Former Property was not destroyed we fail to see how any part of the Taxpayer's POD could reasonably be consideration as compensation for property destroyed. ...

The Additional Services will consist of: (a) identification and risk assessment of Parent's and the Non-Resident Group's global structure, activities and processes; (b) development and implementation of an approved annual audit plan, including any special tasks or projects; (c) maintenance of a professional audit function with sufficient knowledge, skills, experience and professional certifications to meet the standards required by the international professional association Institute of Internal Auditors; (d) evaluation and assessment of significant merging/consolidating functions and new or changing services, processes, operations and control processes coincident with their development, implementation and/or expansion across all jurisdictions; (e) issuance of quarterly reports that summarize the results of audit activities; (f) informing Parent and the Non-Resident Group of emerging trends and successful practices in internal auditing; (g) assisting in the investigation of significant suspected fraudulent activities and notify Parent and/or the Non-Resident Group of the results; (h) consideration of the scope of work of the external auditors and regulators, as appropriate, for the purpose of providing optimal internal audit coverage at a reasonable cost; and (i) provision of an internal auditor that is an employee of Canco. 13. ...