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However, as discussed in paragraph 6 of Interpretation Bulletin IT-484R2 "Business Investment Losses" subsection 50(1) of the Act deems a taxpayer to have disposed of a debt or a share of a corporation at the end of a taxation year for nil proceeds and to have reacquired it immediately thereafter at a cost of nil if: (a) in the case of a debt (other than a debt from the sale of personal-use property), the debt is owing to the taxpayer at the end of the taxation year and it is established by the taxpayer to have become a bad debt in the year; and (b) in the case of a share (other than a share received as consideration from the sale of personal-use property), the taxpayer owns the share of the corporation at the end of the taxation year and the corporation: (i) has become a bankrupt (as defined by the Bankruptcy and Insolvency Act) in the year; (ii) is a corporation referred to in section 6 of the Winding-up Act that is insolvent (within the meaning of that Act) and for which a winding-up order under that Act was made in the year; or (iii) at the end of the year, is insolvent, and neither the corporation, nor a corporation it controls, carries on business. ...

The consideration for the purchase price of Targetco would be an interest-bearing promissory note ("Purchase Note"). ...

Consequently, we will forward a copy of the letter you received from the Superannuation Directorate of the Public Works and Government Services Canada to the Sudbury Tax Services Office for its consideration in respect of your file. ...

These rulings are based on the Act as it currently reads and do not take into consideration any proposed amendments thereto. ...

At the time of incorporation, one (1) common share of VCo will be issued to XXXXXXXXXX for nominal consideration of $XXXXXXXXXX. 5. ...

If the person for whom the training is being provided is both a shareholder and an employee of the corporation, a determination will have to be made, taking into consideration all the relevant facts and circumstances of the particular case, as to whether the training was conferred by the corporation on the person as a shareholder or as an employee. ...

The general approach is to value the various interests taking into consideration the FMV of the property itself, the current interest rates, the life expectancy of any life tenants, and any other factors relevant to the specific case. ...

In order for an amount to be a "gift" at law it must be a voluntary transfer of property without consideration. ...

The consulting fees received or receivable by Petroleum Co. as part payment for the information to be provided by Petroleum Co. to the Grantor of the GOR agreement, and the value of the GOR agreement provided to Petroleum Co. as part consideration for the information to be provided to the grantor of the GOR agreement will be considered as income from an "active business carried on by" Petroleum Co. within the meaning of subsection 125(7). ...

Subsection 70(2) does not apply to the pay equity wage adjustments under consideration since an employee who died prior to obtaining a determinable right to a wage adjustment would not have had a right or thing at the time of death as contemplated by subsection 70(2). ...