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Where it is necessary to make such a determination all the relevant facts must be taken into consideration. ...

Where subsection 160(1) applies to a subsection 75(2) situation, the transferor and transferee are jointly and severally liable to pay a) that part of the transferor's Part l tax, for each taxation year, that is attributable to the subsection 75(2) attribution, and (b) an amount equal to the lesser of (i) the transferor's tax liability for the year in which the property was transferred and for any preceding year, and (ii) the amount by which the fair market value of the transferred property exceeds the fair market value of the consideration given therefor. ...

The fact that no revenue was generated during this period was held not to be a significant consideration in determining whether the business had commenced and was being carried on. ...

The paragraph is also changed to take into consideration the amendment to subsection 70(3.1) enacted under S.C. 1994, c.21 (formerly Bill C-27) for the 1992 and subsequent taxation years. ...

Any use of copyright involved in downloading the product is not an important part of the total consideration paid by the purchaser. ... That is, the lump sum amount will be regarded as having been made or incurred as consideration for insurance for a period after the end of a taxation year. ... Question 3 Are there any other important considerations when a particular property is purchased under a business expansion? ...

Question 7 When requesting an advance income tax ruling on the reasonableness of shareholder/manager remuneration under section 67 of the Act, are there any important considerations that should be kept in mind? ... The courts have described interest in general terms as “the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to... or owed to, another”. ... In this situation, the most important consideration is whether the farm has generated, or can be expected to generate enough income to support the taxpayer's lifestyle. ...

Question 7 When requesting an advance income tax ruling on the reasonableness of shareholder/manager remuneration under section 67 of the Act, are there any important considerations that should be kept in mind? ... The courts have described interest in general terms as “the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to... or owed to, another”. ... In this situation, the most important consideration is whether the farm has generated, or can be expected to generate enough income to support the taxpayer's lifestyle. ...

Any use of copyright involved in downloading the product is not an important part of the total consideration paid by the purchaser. ... That is, the lump sum amount will be regarded as having been made or incurred as consideration for insurance for a period after the end of a taxation year. ... Question 3 Are there any other important considerations when a particular property is purchased under a business expansion? ...

In general, a taxpayer may deduct any amount up to the maximum available for the year taking into consideration any restrictions such as those mentioned in 12, 15 and 23 to 26 below or restrictions on certain types of property such as rental or leasing property (subsections 1100(11) to (20) of the Regulations) or specified leasing property (subsections 1100(1.1) to (1.3) of the Regulations). ... Note: If the draft legislation released by the Minister of Finance on August 30, 1993 is enacted into law as currently proposed, new subsection 13(33) will provide that, for greater certainty, where a person acquires a depreciable property (the acquired property) for consideration that includes a transfer of property (for example, a trade-in), the portion of the cost to the person of the acquired property attributable to the transfer shall not exceed the fair market value of the transferred property. ... This new provision will apply in determining the cost of a depreciable property which a person acquires for consideration that includes a transfer of property (for example, a trade-in). ...

A bonus or premium paid by a mortgagor to a mortgagee in consideration for the mortgagee's consent to an early redemption of the mortgage is considered to constitute an amount paid to a creditor on account or in lieu of payment of any debt and consequently this premium or bonus cannot qualify as an "eligible capital expenditure"; (d) amounts paid or payable by a corporation to a person in his or her capacity as a shareholder. ... Where goodwill, as a recognizable asset, is acquired by the purchaser of a business in the circumstances described in ¶ 6, the consideration given for the goodwill, as well as any legal and accounting fees that can be directly associated with the purchase of the goodwill, will qualify as an eligible capital expenditure. If the portion of the total consideration for the business that is allocated to the goodwill is unreasonable, or if the goodwill has a value which the vendor and purchaser have not specified, the Canada Revenue Agency (CRA) can apply the provisions of section 68 to deem what may reasonably be regarded as the amount for the goodwill. ...