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However, due to the fact that the words being interpreted by the court, i.e. the corporation, are different from those currently under consideration, the outcome of this case is not considered as a precedent in interpreting these words. ...

Upon the wind-up, the acquiring corporation increases the book value of the assets of the acquired corporation by the difference between the consideration paid for the shares of the acquired corporation and book value of those assets. ...

The temporary nature of the trip and ties within Canada have become the vital considerations. ...

In particular, we have insufficient information to enable us to determine how the capital gains will arise; however, in general, by virtue of paragraphs 86(1)(b) and (c) no capital gains will arise on a section 86 reorganization of capital where the only consideration received by the taxpayer is shares of another class of the capital stock of the corporation. ...

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. ...

The comments set out in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

The limited partner pays a reasonable guarantee fee to the partnership as consideration, as well as provides an indemnity saving the partnership harmless from any loss or cost it may suffer as a result of the guarantee. ...

The application of these provisions to a particular case can only be made after thorough consideration of all of the relevant facts pertaining to that situation. ...

--the aggregate of all amounts each of which is an amount paid by or on behalf of the taxpayer in the year or within 60 days after the end of the year (i) as a premium under a registered retirement savings plan under which he is the annuitant, (ii) to acquire, from a person licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada an annuities business, an annuity (A) under which the taxpayer is the annuitant (I) for the taxpayer's life, or for the lives jointly of the taxpayer and the taxpayer's spouse (in this paragraph having the meaning assigned by subsection 146(1.1)), either with a guaranteed period that is not greater than 90 years minus the age of the taxpayer or the age of the taxpayer's spouse, at the time of its acquisition or without a guaranteed period, or (II) for a term of years equal to 90 minus the age of the taxpayer or the age of the taxpayer's spouse, at the time of its acquisition, or (B) under which the taxpayer, or a trust under which the taxpayer is the sole person beneficially interested in all amounts payable under the annuity, is the annuitant for a term of years not exceeding 18 minus the age of the taxpayer at the time of its acquisition that does not provide for any payment thereunder except (C) the single payment by or on behalf of the taxpayer, (D) equal annual or more frequent periodic payments commencing not later than one year after the date of the payment referred to in clause (C), and (E) payments in full or partial commutation of the annuity and, where the commutation is partial, equal annual or more frequent periodic payments thereafter, or (iii) to a carrier as consideration for a registered retirement income fund under which the taxpayer is the annuitant where such aggregate (iv) is designated by the taxpayer in his return of income under this Part for the year, (v) does not exceed the aggregate of (A) the amount included in computing his income for the year as a refund of premiums out of or under a registered retirement savings plan under which the taxpayer's spouse was the annuitant, (B) the amount included in computing his income for the year as a refund of premiums out of or under a registered retirement savings plan where the taxpayer was dependent by reason of physical or mental infirmity on the annuitant under the plan, (B.1) the lesser of (I) the amount paid by or on behalf of the taxpayer to acquire an annuity that would be described in subparagraph (ii) if that subparagraph were read without reference to clause (A) thereof, and (II) the amount (other than any portion thereof included in the amount determined under clause (B)) included in computing the taxpayer's income for the year as a payment (other than a payment that is part of a series of periodic payments or that relates to an actuarial surplus) received by the taxpayer out of or under a registered pension plan, or as a refund of premiums out of or under a registered retirement savings plan, as a consequence of the death of an individual, where the taxpayer is a child or grandchild of the individual, and (B.2) the amount included in computing the taxpayer's income for the year that was received by the taxpayer as a consequence of the death of the taxpayer's spouse out of or under a provincial pension plan prescribed for the purposes of paragraph (v), and, where the amount is paid by a direct transfer from the issuer of a registered retirement savings plan or a carrier of a registered retirement income fund, (C) the amount included in computing his income for the year as a consequence of a payment described in subparagraph 146(2)(b)(ii), and (D) the portion of the amount received by him out of or under a registered retirement income fund and included in computing his income for the year by virtue of subsection 146.3(5) that exceeds the minimum amount (within the meaning assigned by paragraph 146.3(1)(b.1)) required to be paid to the annuitant in the year under that fund, and (vi) was not deducted in computing his income for a preceding taxation year; ...