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Notwithstanding our comment above, in a situation where the surplus balances are increased or decreased inappropriately, consideration will also be given to the application of specific anti-avoidance rules as well as the General Anti-Avoidance Rule in section 245 of the Act. ...

In the current case, paragraph 105(1)(b) has no application as the provision does not apply to an interest in a personal trust that has never been acquired for consideration. ...

CRA Response a) Assuming that the foreign entity is a trust for Canadian tax purposes and that this foreign entity's beneficial interests (hereafter "capital interest") were acquired for consideration, there might be a reduction in the adjusted cost base (ACB) of the capital interest in accordance with subparagraph 53(2)(h)(i.1) of the ITA where an amount has become payable to the beneficiary in respect of his interest and where this amount is not the proceeds of disposition of the interest or part thereof, and this, to the extent that the amount or part thereof, is not subject to one of the exceptions provided in this subparagraph. ...

In broad terms, this requires a consideration of the intent of the annexation to the building. ...

As consideration for the assets transferred to it, CFA5 will assume the liabilities associated with these assets (as recorded in CFA4's financial statements immediately before the transfer) and will issue CFA4 a promissory note having a face value equal to the Transfer Amount less the amount of the liabilities assumed by it. ...

In calculating the time spent performing duties on a reserve, the same considerations apply with respect to proration as with respect to Guideline 3. ...

1-2 C) Est-ce que la filiale doit prendre en considération le CBR de Mèreco dans le calcul de son CDC et vice versa? ...

In Cloutier, the Court mentions the following on pages 225 and 226: To begin with, I do not think it is appropriate in interpreting social legislation like the Unemployment Insurance Act to adopt an approach similar to that required to give effect to fiscal legislation, the reason being that the same considerations do not apply in giving effect to these two types of legislation. ...

L'ARC peut prendre en considération la régularité du déplacement et la nature des tâches pour déterminer si un endroit est effectivement le lieu de travail habituel. ...

In general terms, the amounts described in paragraphs (a) and (b) of the value for "A" will reflect 63% of the total of the corporation's "full rate taxable income" for each taxation year of the corporation ending after 2000 and before 2006, with certain modifications depending on the taxation year in question, determined before taking into consideration the specified future income tax consequences for the year. ...