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It nevertheless remains an important consideration in establishing as accurately as possible a picture of profit. ...

The other 70% of the interests in Partnership were held by persons who deal at arm's length with Canco, FA1 and FA2. 3) In year 4, FA2 purchased the other 70% of the interests in Partnership for fair market value consideration. ...

The above ruling, which is based on the Act in its present form and does not take into consideration any proposed amendments thereto, is given subject to the general limitations and qualifications set out in Information Circular 70-6R3 dated December 30, 1996, and is binding on Revenue Canada provided that the proposed transactions are completed within six months of the date of this letter. ...

With respect to the amalgamation of Transferee2 and Subco3 described in paragraph 35A above: (a) the provisions of subsection 87(1) will apply; and (b) subsection 87(1.1) will, for the purposes of paragraph 87(1)(c) and the Income Tax Application Rules, deem the Transferee2 Common Shares to be NewTransferee2 Common Shares received by the shareholder as consideration for the disposition of the Transferee2 Common Shares. 18. ...

This determination required a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...

" This is not, in my opinion, descriptive of the transactions involving letters of credit that are under consideration in this appeal. ...

L’ARC peut prendre en considération la régularité du déplacement et la nature des tâches pour déterminer si un endroit est effectivement le lieu de travail habituel. » Aussi, le Guide de l’employeur T4130 (footnote 3) sous la rubrique « Lieu de travail habituel » indique notamment ce qui suit: « Un lieu de travail habituel est tout endroit où votre employé se présente habituellement pour travailler ou exercer ses fonctions d’emploi. ...

A in Year 2 would not constitute an “excluded amount” and would, absent any other consideration, be considered split income of Mr. ...

These factors, among others, would need to be taken into consideration to determine if the primary purpose of the award is to further the education and training of the recipient or if specific work is being conducted by the student where the primary purpose is to benefit the research activities of the University. ...

Our above view is consistent with CRA’s previous TIs XXXXXXXXXX, which dealt with subsection 403(3), and, in general, opined that the determination of a PE for the reasonable attribution purposes involves consideration of various factors such as the location of origin and servicing of the policies involved and the location which negotiated the contract of reinsurance and on whose books the liability for the risk is recorded (which may be the company's head office in most cases). ...