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The Lossco Preferred Shares, will not be at any time during the implementation of the Proposed Transactions described herein (a) the subject of any undertaking that is referred to in subsection 112(2.2) of the Act as a "guarantee agreement"; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act, other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or (e) any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act; or a share that is issued or acquired as part of a transaction or series of transactions or events of the type described in subsection 112(2.5) of the Act. 24. ...

The individual received an amount of $100,000 cash as consideration for the disposition (being the ACB of the shares of Corporation B) and shares of PORTCO (for the difference between $100,000 and the FMV of the shares of Corporation B at the time of the transfer). ...

The Preferred Shares Series 2 of Newco which will be issued as described in 10 above, will not be, at any time during the implementation of the proposed transactions described in 10 to 19 above: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a "guarantee agreement"; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: A) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or B) any right of the type described in subparagraph 112(2.4)(b)(ii). 24. ...

En effet, nous ne croyons pas que la contribuable participe aux activités sportives précitées pour de simples raisons commerciales mais également pour des considérations d'ordre personnel (notamment pour l'amour du sport, le dépassement de soi et la possibilité de participer aux Jeux Olympiques). ...

LP is located within the area served by the XXXXXXXXXX TSO and the XXXXXXXXXX TC; (w) "LP Agreement" means the limited partnership agreement dated XXXXXXXXXX, as amended, which governs LP; (x) "LP Operations" means the operations of LP which consists in the XXXXXXXXXX and the ownership of an indirect interest in Canco A and Canco B through Holdco; (y) "LP Guarantee" means the agreement or agreements to be entered into by LP with the Lenders pursuant to which LP will provide to the Lenders a guarantee of the obligations of Finco under the Credit Facility secured by a charge over the assets of LP; (z) "LP Loan Amount" means the sum of approximately $XXXXXXXXXX to be advanced by Finco to LP pursuant to the LP Sub-Loan Agreement using a portion of the funds drawn by Finco from the Credit Facility; (aa) "LP Sub-Loan Agreement" means the agreement to be entered into between Finco and GP, in its capacity as general partner of LP, outlining the terms and conditions of the loan by Finco in favour of LP of the LP Loan Amount; (bb) "Paragraph" means a numbered paragraph in this advance income tax ruling; (cc) "Preferred Shares" means the preferred shares of Canco A to be acquired by Holdco from Canco D under the Share Purchase Agreement; (dd) "Share Purchase Agreement" means the agreement to be entered into between Holdco and Canco D pursuant to which Holdco will agree to acquire the Preferred Shares which are currently held by Canco D for a total consideration of approximately $XXXXXXXXXX payable in cash; (ee) "Sub Guarantees" means, collectively, the LP Guarantee and the Holdco Guarantee; (ff) "Sub-Loan Agreements" means, collectively, the LP Sub-Loan Agreement and the Holdco Sub-Loan Agreement; (gg) "taxable Canadian corporation" has the meaning assigned by subsection 89(1) of the Act. ...

La Reine, 2002 DTC 2065 (CCI) (ci-après "Ahmad"), le juge Miller qui avait à décider si les intérêts avant jugement reçus par un contribuable relativement à des dommages-intérêts étaient imposables, a statué comme suit sur le sens à donner au mot "intérêt": The starting point for the determination of the nature of an interest payment is the oft-cited definition of the Supreme Court of Canada in Re The Validity of Section 6 of the Farm Security Act, 1944 of the Province of Sasketchewan: Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another... ...

The Preferred Shares of Newco which will be issued as described in paragraph 10 above, will not be, at any time during the implementation of the proposed transactions described herein: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a "guarantee agreement"; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: A) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or B) any right of the type described in subparagraph 112(2.4)(b)(ii). 19. ...

Although the reorganization was delayed due to a markedly increased level of activity with respect to Pubco's XXXXXXXXXX and financing activities, the Board of Directors of Pubco has now submitted the Proposed Transaction to Pubco's shareholders for consideration at the annual and special general meeting of shareholders which was held on XXXXXXXXXX. ...

XXXXXXXXX, B Co acquired, under an assignment agreement with A Co for consideration consisting of cash and a promissory note, all of A Co's interest in the Project. ...

In consideration for these services the Partnership pays the associates a per-diem amount or a negotiated fee-for-service. ...