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In the case under consideration, a minimum dividend entitlement of `$10 million would be paid on the Class A shares if the directors were to declare a $12 million dividend. ...

under the terms of the Plan, n employee is required to dispose of his shares of Opco issued under the Plan (the "Purchased Shares") for fair market value consideration upon the cessation of his employment.  ...

The income calculated by a partnership pursuant to paragraph 96(1)(f) of the Act must take into consideration the partnership's election under paragraph 34(a) of the Act.  ...

The $1 million in the capital account will be the net result of various additions to and reductions from that account, and these adjustments would have been taken into consideration for tax purposes by way of adjusting the ACB of A Co.'s partnership interest.  ...

Dans la note de service mentionnée ci-dessus (dossier #7-3945), la section des institutions financières énonçait que le produit de disposition, pour le prêteur de valeurs mobilières, était égal à:      "The proceeds from the disposition bv 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 specific time for further consideration." ...

For greater certainty, no part of the Equalizing Payments will be made as consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any patent, trade-mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. ...

In reaching this conclusion, the Court stated:      "Where the income under consideration is part of the normal business activity of a company and it is inextricably linked with an active business it is considered active business income.  ...