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Pursuant to paragraph 4 of Article XVIII of the Convention, "annuity" is defined in to mean, "...a stated sum paid periodically at stated times during life or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered), but does not include a payment that is not a periodic payment or any annuity the cost of which was deductible for the purposes of the taxation in the Contracting State in which it was acquired. ...

Pursuant to paragraph 4 of Article XVIII of the Convention, "annuity" is defined in to mean, "...a stated sum paid periodically at stated times during life or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered), but does not include a payment that is not a periodic payment or any annuity the cost of which was deductible for the purposes of the taxation in the Contracting State in which it was acquired. ...

The two amounts which will reduce a taxpayer's capital gain otherwise determined are the principal residence exemption, determined in the usual way, and the lesser of the reported taxable capital gain, which is the taxable capital gain that was reported when the election was filed, and the maximum taxable capital gain, which is the taxable capital gain that would have resulted from the election if the principal residence designations made in respect of the property covered by the election for years prior to 1995, regardless of whether they were made in the 1994 tax return or in a return for a subsequent year, were taken into consideration. ...

Paragraph 4 of Interpretation Bulletin, IT-441 (the "Bulletin") states that: "a disposition of a film or tape will be considered to take place where the investor grants to a person or persons the right to distribute or otherwise exploit the film or tape in markets representing most or all of the exploitable value of the film or tape for a fixed amount of consideration which can reasonably be considered to be its fair market value". 2. ...

This determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...

While the determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor, the major determining factor is the source of the income. ...

In such circumstances, in our view, it must be taken into consideration that where an arrangement creates an artificial connection between business income and a reserve, the arrangement will carry no weight as a connecting factor. ...

This determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...

Whether an amount received as a gift or prize is taxable is a question of fact which can only be determined by analyzing all of the circumstances in a given situation Generally, however, amounts received as gifts (that is, voluntary transfers of real or personal property without consideration) or prizes are not subject to tax in the hands of the recipient. ...

A sold the shares of ACo to the ABC Partnership in exchange for fair market value cash consideration. ...