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Principal Issues: Whether, in a particular situation where a corporation ("USCO") grants to another corporation ("CANCO") options to purchase additional shares of USCO's capital stock and such options are not granted in consideration for services previously rendered, subsection 15(1) would apply to CANCO at the time of the granting of such options and/or at the time of their exercise. ...

The premium paid on the purchase of a bond is added to its ACB, and any amount deducted under ss. 20(14) of the Act reduces the ACB. (3) The owner of a strip bond is required to include the interest that accrued at the end of the anniversary day of the contract (ss. 12(4) of the Act) and that amount is included in the ACB of the bond (ss. 52(1) of the Act. (4) An estate may deduct the amounts payable to a beneficiary and the appropriate T3 or NR4 slips have to be issued. (5) Various considerations. ...

It is a question of fact as to whether the children would be considered to meet the excluded business test with consideration given to the nature, and the labour requirements of Investco’s business. ...

At the time of transfer of a portion of the property to an adult child for no consideration, where the property has increased in value, a capital gain is determined and the provisions of subparagraph 69(1)(b)(ii) of the Act are applicable. ...

For instance, you indicate that the merit of the musician's proposed project is one of the considerations for receiving the award; however, it is unclear how much weight is allocated to this factor and which other factors are considered. ...

While certain auctioneers may as a practical consideration defer payment to the vendor until such time as the purchaser's cheque has cleared, this does not change the position that the funds belong to the vendor as of the time the auctioneer has declared the livestock to be sold. ...

This would entail consideration of the specific facts, including the identities of the parties and any non-arm's length relationships between any of them. ...

Il reste que les modalités de la Police doivent être prises en considération avant de faire une détermination à cet égard. ...

We offer the following general comments for your consideration. It is not clear whether the "in trust" accounts are trusts for income tax purposes. ...

The position, therefore, provides alternatives, rather than restrictions, in the calculation of an allowance for purposes of subsection 81(3) of the Act, by taking into consideration the provisions of provincial Municipal Acts and local by-laws. ...