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Reasons: 1) The amounts received are in consideration for goods provided pursuant to the terms of a contractual arrangement between the taxpayer and the Ontario Power Authority and / or local utility company. 2) Consistent with the comments provided in IT-120R6. 2008-027535 XXXXXXXXXX Bob Naufal (613) 957-2097 September 25, 2008 Dear XXXXXXXXXX: Re: Installation of a Solar Panel Roof We are writing in response to your letter dated April 14, 2008 to the Sudbury Tax Services Office and forwarded to our Directorate on April 17, 2008 for response. ...

Here are the words of the FCA majority to this effect: "I would agree with the respondent, but only to the extent that subdivision restrictions, or for that matter minimum site requirements, in force at the date of disposition cannot be determinative of the issue under consideration. ...

20 November 2008 External T.I. 2008-0296181E5- renewable Energy Projects- Tidal Energy Unedited CRA Tags Ewg 1100; reg 1219(1); 66(15) Principal Issues: Discussion of tax incentives available for renewable energy projects-- tidal wave energyprojects- tidal wave energy Position: general discussion XXXXXXXXXX 2008-029618 Lena Holloway November 20, 2008 Dear XXXXXXXXXX Re: Renewable Energy Projects- Tidal Energy We are writing in response to your e-mail correspondence of October 7, 2008, requesting information on any special income tax considerations concerning tidal energy projects. ...

The Taxpayer's indebtedness includes: i) the Funding Notes, which were issued by the Taxpayer to Lender as partial consideration for the acquisition of common shares of Can Holdco from Lender; and ii) the Funding Loan, which the Taxpayer borrowed from Lender, the borrowed money of which was used by the Taxpayer to subscribe for additional common shares of Can Holdco at fair market value. 7. ...

Factors taken into consideration to determine if a corporation is engaged in construction includes whether the construction industry would view the corporation's overall activities as construction activities and the use of construction equipment (e.g., trucks, tractor trailers, rollers). ...

The Paid-up Capital of the Classes of Shares is made up of the sum of the amounts of cash and of the fair market value of the property contributed in favour of ACo in consideration for the issuance of the shares of any of the Classes of Shares, which amounts were added to the Capital, reduced by the amount of any reduction of Capital effected by ACo in favour of the Shareholders XXXXXXXXXX None of the Paid-up Capital of the Classes of Shares is derived from the capitalization of Pre-1972 CSOH in respect of which an election has been made in accordance with the provisions of subsection 83(1) as it read with respect to dividends which became payable before 1979. 4. ...

29 May 2007 Internal T.I. 2007-0223381I7 F- Capital Dividend Account Unedited CRA Tags 83(2) 89(1) 87(2)(z.1); 88(2)(e.2) Principal Issues: In a given fact situation, where a wholly-owned subsidiary is wound-up in its parent corporation and both parent and subsidiary have a CDA immediately before the winding-up, whether the parent must take into consideration the different amounts of its subsiduary's CDA in computing its CDA immediately after the wind-up. ...

The purpose of the Proposed Transactions is to enable Holdings to acquire indirectly approximately XXXXXXXXXX% (but not less than XXXXXXXXXX%) of the units of LP and, in doing so, acquire indirectly XXXXXXXXXX% (but not less than XXXXXXXXXX%) of the businesses operated by OP in as efficient a manner as possible, taking into account securities and other business-regulatory requirements and income-tax considerations in multiple jurisdictions including Canada. ...

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX. 8. ...

La Loi sur les sociétés par laquelle est régie la société, le registre des actionnaires, les statuts et règlements de la société de même que la convention unanime des actionnaires sont des éléments qu'il importe de prendre en considération pour déterminer le contrôle de droit d'une société. ...