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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. ...

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. ...

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. ...

In determining whether any location visited by a Staff could be a RPE, consideration should be given as to how often a particular townhouse complex or apartment building is visited, and not any individual unit located within the townhouse complex or apartment building. ...

Furthermore, as discussed in paragraph 3 of Interpretation Bulletin IT-339R2, a PHSP must contain the following basic elements: i)     an undertaking of one person, ii)     to indemnify another person, iii)     for an agreed consideration, iv)     from a loss or liability in respect of an event, v)     the happening of which is uncertain. ...

You have also noted the situation in which a drawer discounts a banker's acceptance that is issued in its name for which it receives the present value of the acceptance in consideration for its promise to compensate the holder of the acceptance should the bank dishonour it. ...

In this regard, you have asked us to confirm that Safe Income attributable to a deemed dividend on the redemption of high-low preferred shares that were received as consideration for shares which had a Safe Income entitlement is fixed at the point in time that the preferred shares are issued, and does not change over time in relation to changes in the fair market value of the corporation and its shares. ...

If the circumstances of the conversion are such that the shares have been disposed of by the shareholders in consideration for membership interests, we note that section 51 would apply only if a membership interest qualified as a “share of the capital stock” of the corporation. ...

First, all potentially relevant factors that connect the property to a location are identified and then each factor is given weight in light of three considerations: the purpose of the income tax exemption, the type of property, and the taxation of that property. ...

First, potentially relevant factors that connect the income to a location are identified and then each factor is given weight in light of three considerations: the purpose of the income tax exemption, the type of property, and the taxation of that property. ...