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Maurice Bisson (613) 957-2099 Le 9 octobre 2009 2009-033002 ROUND TABLE ON THE FEDERAL TAXATION APFF- 2009 CONFERENCE Question 6 Application of Subsection 5(2) of the EIA Last year, in question 32 of the Round Table, the CRA stated in its response, that for the purposes of the application of paragraph 5(2)(b) of the Employment Insurance Act (EIA), one must consider all the classes of voting shares of the corporation and also take into consideration the number of votes allocated to each share. ...

Clearly, a material change includes a false declaration or a significantly relevant event that would allow for the consideration of whether paragraphs 6(a) or (b) of Article XXIX-A of the Convention applied or would continue to apply. ...

In a situation such as yours involving a trailer, consideration should be given to the case, Windrim v. ...

Lipson and analyzed by the Supreme Court of Canada in January 2009, in the following hypothetical scenarios: (i) Instead, the individual makes an election for the transfer of shares at FMV to his spouse and receives consideration equal to the FMV; (ii) The individual applies the exact strategy of Mr. ...

According to the Agreement, the Employer agreed to pay a Settlement Amount to the employees “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ...

Consideration of such terms would not be limited to the right to exploit the results of the SR&ED or be reimbursed for the SR&ED expenditures. ...

Pursuant to the Order, and as consideration for the termination of the Complaint and the settlement of the Grievances, each Eligible Employee will receive a lump-sum payment. ...

As part of a corporate reorganization in XXXXXXXXXX, Parent contributed all of the issued and outstanding shares of Foreignco to DC for consideration that consisted solely of additional membership interests in DC. ...

In determining the existence of commercial coherence, factors that would be relevant include: 1) whether the projects would, in the absence of tax planning considerations, have been concluded pursuant to a single contract; 2) whether the nature of the work involved under different projects is the same; and 3) whether the same individuals are providing the services under the different projects. ...

For the purposes of the application of paragraph 5(2)(b) of the EIA, the CRA considers all the classes of voting shares of the corporation and also takes into consideration the number of votes allocated to each share. ...