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It is your understanding that there is no necessity to determine whether Company B is operating a single business or more than one with respect to the sale of products X and Y so long as only the income generated from the similar product, X, is taken into consideration for the purposes of subparagraph 111(5)(a)(ii) of the Act. ...

(ii) using Leasing is defined in Article 1600 of the Civil Code as "a contract by which the lessor binds himself towards the lessee to grant him the enjoyment of a thing during a certain time, for a consideration, the rent". ... In the memorandum referred to above (file #7-3945) the Financial Institutions section stated that the proceeds of disposition to the short seller of the securities were as follows: The proceeds from the disposition by the lender would be equal to the value of the consideration received i.e. the value of the right to require delivery of identical shares at a specified time for no further consideration. ...

(ii) Leasing Leasing is defined in Acticle 1600 of the Civil Code as "a contract by which the lessor binds himself towards the lessee to grant him the enjoyment of a thing during a certain time, for a consideration, the rent". ... In the memorandum referred to above (file #7-3945) the Financial Institutions Section stated that the proceeds of disposition to the short seller of the securities were as follows: The proceeds from the disposition by the lender would be equal to the value of the consideration received i.e. the value of the right to require delivery of identical shares at a specified time for no further consideration. ...

(ii) Leasing Leasing is defined in Article 3600 of the Civil Code as "a contract by which the lessor binds himself towards the lessee to grant him the enjoyment of a thing during a certain time, for a consideration, the rent". ... In the memorandum referred to above (file #7-3945) the Financial Institutions Section stated that the proceeds of disposition to the short seller of the securities were as follows: The proceeds from the disposition by the lender would be equal to the value of the consideration received i.e. the value of the right to require delivery of identical shares at a specified time for no further consideration. ...

We have brought this to the attention of the Department of Finance for their consideration. ... On the next revision to interpretation bulletin IT-428 "Wage Loss Replacement Plans," consideration will be given to including some additional comment on the shareholder versus employer aspect. ...

Each shareholder of OPCO will transfer his shares of OPCO to NEWCO for consideration comprising shares of NEWCO having a fair market value equal to the fair market value of the shares of OPCO so disposed of by him and will elect, jointly with NEWCO, to have the provisions of subsection 85(1) of the Act apply to the transfer. ... Each of the three individuals will transfer the shares of the HOLDCO owned by him to OPCO for sole consideration comprising shares of OPCO having a fair market value equal to the fair market value of the shares of the HOLDCO so disposed of by him and will elect, jointly with OPCO, to have the provisions of subsection 85(1) of the Act apply to the transfer. ...

The application of these provisions to a particular case can only be made after thorough consideration of all of the relevant facts pertaining to that situation. ... Whether a particular asset is capital property used by a person in carrying on a business (other than an insurance business) in Canada such that the asset is taxable Canadian property by virtue of subparagraph 115(1)(b)(ii) is essentially a question of fact that can only be answered after determination of all relevant facts pertaining to the particular case under consideration. ...

A new corporation ("NEWCO") will be incorporated to be the holding corporation, Each shareholder of OPCO will transfer his shares of OPCO to NEWCO for consideration comprising shares of NEWCO having a fair market value equal to the fair market value of the shares of OPCO so disposed of by him and will elect, jointly with NEWCO, to have the provisions of subsection 85(1) of the Act apply to the transfer, The amount agreed upon by a shareholder and NEWCO in their election may result in a shareholder realizing a capital gain on the disposition of his shares of OPCO to NEWCO, and the shareholder intends to claim an amount in respect of any such capital gain pursuant to either subsection 110.6(2.1) or (3) of the Act, OPCO will then declare and pay a taxable dividend to NEWCO equal to "income earned or realized by OPCO after 1971" ("Safe Income") on hand prior to the transfer of shares described above. ... Each of the three individuals will transfer the shares of the HOLDCO owned by him to OPCO for sole consideration comprising shares of OPCO having a fair market value equal to the fair market value of the shares of the HOLDCO so disposed of by him and will elect, jointly with OPCO, to have the provisions of subsection 85(1) of the Act apply to the transfer, The amount agreed upon by an individual and OPCO in their election may result in the individual realizing a capital gain on the disposition of his shares of a HOLDCO to OPCO, and the individual intends to claim an amount in respect of any such capital gain pursuant to either subsection 110.6(2.1) or (3) of the Act, Under the Company Act, combining two corporations by winding up one corporation into the other corporation is simpler than amalgamating them, because the Company Act does not provide for a "short-form" amalgamation procedure, Each HOLDCO will therefore be wound up into OPCO in a winding-up to which subsection 88(1) of the Act will apply. ...

XXXXXXXXXX will transfer its shares of XXXXXXXXXX to Newco at net book value for United Kingdom tax purposes in exchange for consideration including intercompany debt. Newco will then immediately transfer its shares of XXXXXXXXXX to BV for fair market value consideration that comprises solely shares in BV. 19. ...

The application of these provisions to a particular case can only be made after thorough consideration of all of the relevant facts pertaining to that situation. ... Whether a particular asset is capital property used by a person in carrying on a business (other than an insurance business) in Canada such that the asset is taxable Canadian property by virtue of subparagraph 115(1)(b)(ii) is essentially a question of fact that can only be answered after determination of all relevant facts pertaining to the particular case under consideration. ...