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In order to clarify the CRA's position, and taking into consideration the new facts outlined above: (i) Will subsection 75(2) ITA apply to the income, losses, taxable capital gains and deductible capital losses derived by Trust X from Corporation Y's shares so as to allocate these amounts to Corporation Y? ...

Société A a émis le XXXXXXXXXX à des Indiens résidant sur une réserve ou ailleurs des obligations pour un montant total de XXXXXXXXXX $ en contrepartie d'une considération globale de XXXXXXXXXX $. ...

In Canadian jurisprudence relating to the Act, the concept of de facto adoption has received consideration. ...

As consideration for the equity interest in the Joint Venture transferred to it by Canco, Newco will issue additional shares to Canco. ...

After extensive negotiations, a new compensation plan was developed that resulted in the discontinuance of the banking and accrual of SDO's effective XXXXXXXXXX, and in consideration for which the Council approved a general wage increase of XXXXXXXXXX% for all Employees. 23. ...

13 May 2005 External T.I. 2005-0126531E5 F- Capital Gain Strip/Significant Increase Unedited CRA Tags 55(3)(a)(i) 55(3)(a)(v) Principales Questions: In a given situation, where Holdco's shareholder and Employeeco's common shareholders are not related to each other, Holdco and Employeeco each own 50% of Opco's common shares, Holdco controls Employeeco and owns all Employeeco high-low redeemable preferred shares which Holdco acquired over a 5 year period as consideration for the rollover transfer each year of 10% of its Opco common shares, and Employeeco redeems part of its preferred shares owned by Holdco, whether 55(2) applies? ...

Where the transactions in question relate to an acquisition of an interest in a property which constitutes a CRP, the consideration given for the acquisition of the interest would generally constitute the cost of a CRP to the purchaser [such interest being a CRP under paragraph (g) to the definition thereof in subsection 66(15) of the Act, subject to the exceptions contained therein] and proceeds of disposition of an interest in a CRP to the vendor [in a mineral resource context such proceeds being included in the determination of item F of the cumulative CDE of the vendor as defined under subsection 66.2(5) of the Act, subject to the express exceptions contained therein]. ...

(d) As consideration for the Guarantee, Foreign Bank will pay FA2 a monthly fee (the Guarantee Fee) based on a percentage of the collateral. ...

Également, la présomption de propriété contenue à la fin paragraphe 80.01(2) doit être prise en considération dans la détermination de ce moment. ...

Canadian Parent will issue such shares in consideration for a cash subscription price of $XXXXXXXXXX received from each of Foreign Sub2 and Foreign Sub3. 13. ...