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In determining whether a taxpayer is an employee or self-employed person, consideration is generally given to the following four criteria: (1) the extent to which the worker is subject to the control of the payor, (2) whether the worker provided his or her own tools, (3) whether the worker has a chance of profit or risk of loss, (4) whether or not the worker is employed as part of the business and performing services integral to the business. ...

On XXXXXXXXXX, the following transactions occurred: (a) Subco 2 issued to Pubco XXXXXXXXXX common shares and XXXXXXXXXX warrants to purchase common shares in Subco 2 in exchange for XXXXXXXXXX new treasury shares and XXXXXXXXXX share purchase warrants of Pubco; and (c) Subco 2 agreed to acquire a XXXXXXXXXX % interest in certain XXXXXXXXXX and, in exchange, to provide consideration that includes the issuance of XXXXXXXXXX common shares, $XXXXXXXXXX, XXXXXXXXXX Pubco common shares and a total of $XXXXXXXXXX of exploration expenditures. 15. ...

X) giving that employee the right to acquire common shares of the capital stock of Opco for a consideration of $1. ...

For example, this could be the case where shares are issued by a corporation for consideration that is less than the fair market value of the said shares. ...

That is, in order for a particular property to be considered a replacement property, there must be a causal relationship between the acquisition and disposition of the properties under consideration. ...

D would dispose of his shares of the capital stock of Opco to Holdco in consideration for the issuance of one non-voting preferred share of the capital stock of Holdco and a note. ...

We would like to mention that our review did not include consideration of GST implications. ...

This is the previous table which is amended to take into consideration the effect of section 257 of the ITA. 2006 2007 2008 2009 According to scenario 1: Element A of the definition of annual gains limit 0 0 0 150,000 Element B of the definition of annual gains limit 0 100,000 0 0 Annual gains limit (A-B) 0 nil 0 150,000 Cumulative gains limit 0 nil nil 150,000 According to scenario 2: NO MODIFICATION Element A of the definition of annual gains limit 0 0 0 150,000 Element B of the definition of annual gains limit 0 0 0 0 Annual gains limit (A-B) 0 0 0 150,000 Cumulative gains limit 0 0 0 150,000 François Bordeleau (613) 957-2082 October 9, 2009 2009-033024 ...

By taking the aforementioned into consideration and by assuming that the other conditions stated in Interpretation Bulletin IT-148R3 are complied with, can the CRA indicate to us if the reduction in the rate of absenteeism or the increase in the productivity of its employees brought about by the employer, is sufficient to determine that there would be no taxable benefit imposed on the employees benefiting from a payment or reimbursement by the employer of the club dues or membership fees? ...

In common law jurisdictions, the courts have said that a bona fide gift exists when there is a voluntary transfer of property without consideration. ...