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POSITION OF THE DEPARTMENT OF FINANCE 1) From a tax policy perspective, it is clear that each expenditure under consideration as an SR&ED expenditure must meet the required criteria (i.e., it must meet the tests in subparagraph 37 (7) (c) (ii)). ...

In so far, however, as the capital additions and improvements were received as consideration for agreeing to deliver 60 cycle power at a price that was lower than would otherwise have been economic, I should be inclined to think that it was probably received on revenue account in accordance with the ordinary principles of commercial trading. ...

The foregoing factors will be taken into consideration when making a determination. ... At the beginning of year 3, the Canadian corporation would acquire the limited partnership interest from the limited partner at fair market value and would give common shares as consideration. ...

Economic considerations dictated the sale in 1951. His Honour held that the profit on sale was made in the carrying on of the company's business and was assessable as a profit according to the ordinary usages and concepts of mankind. ... One important consideration in buying shares was that they should immediately- or within a reasonable period- produce a dividend yield of 4% or better. ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information This example illustrates why losses of corporations in a corporate group must be included in the computation of consolidated income earned or realized.5 The same result would obtain if, sometime before the relevant time, A Co had sold the shares of C Co to B Co for nominal consideration. ... Investment Tax Credit Depreciable Property A corporation that has acquired a property, or made an expenditure, the specified percentage of which is included in its investment tax credit as defined in subsection 127(9) may claim a deduction from its tax otherwise payable under Part I of the Act as permitted in subsection 127(5), or it may be deemed by subsection 127.1(1) to have paid an amount on account of its tax under Part I of the Act, which amount is deemed to have been deducted under subsection 127(5). 1) Subsection 13(7.1) A incorporates A Co and subscribes for common shares for consideration of $100. ...

This is apparently the case as, taking into consideration the various business corporations acts, this structure affords creditors with the most security with respect to the distress preferred shares received in substitution for their debt. ...

P A R T II Transfers for Inadequate Consideration (85(1)(e.2); 86(2); 87(4) and 51(2)) The corporate reorganization sections in the Income Tax Act contain provisions which impose "penalties" for transfers to or share exchanges with corporations where the value of the property given up exceeds the value of the property received, and "it is reasonable to regard any part of such excess as a benefit that the taxpayer desired to have conferred on a person related to the taxpayer. ...

The initial limited partner has purchased one unit of the Partnership for a consideration of $XXXXXXXXXX as its capital contribution to the Partnership. ...

Dans ce bulletin, nous indiquons que la situation financière de tous les membres d'un groupe lié de corporations doit être prise en considération pour établir si l'on peut raisonnablement croire qu'un des membres est sur le point de manquer aux engagements résultant d'une dette obligataire en raison de difficultés financières. ...

Quoique les raisons commerciales puissent abonder, il est clair que les considérations fiscales jouent également un rôle important dans la conception des régimes.  ...