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(ii) the development of real estate for sale, the lending of money, the leasing or licensing of property or the insurance or reinsurance of risks, and (b) the affiliate...employs (i) more than 5 employees full time in the active conduct of the business, or (ii) the equivalent of more than 5 employees full time in the active conduct of the business taking into consideration only the services provided by its employees of (A) a corporation related to the affiliate (otherwise than because of a right referred to in paragraph 251(5)(b)),... where the corporation...referred to in clause (A) receive compensation from the affiliate...for the services provided to the affiliate...by those employees the value of which is not less than the cost to such corporation...of the compensation paid or accruing to the benefit of those employees that perform the services during the time the services were performed by those employees. ...

While the residence status of an individual can only be determined on a case by case basis after taking into consideration all of the relevant facts (please refer to Interpretation Bulletin IT-221R3, "Determination of an Individual's Residence Status" which is available on our website at www.ccra-adrc.gc.ca for a detailed discussion of such facts), it appears that an employee who commutes to work in New York state but returns to his or her home in Canada each night after work would most likely be considered factually resident in Canada. 2. ...

., a U.S. public corporation, agreed to advance up to $5 million to Alias in consideration of a security interest in Alias' assets and the issuance of warrants to acquire common shares of Alias. ...

Toutefois, l'ADRC est disposé à prendre en considération tous les autres facteurs pertinents, incluant la valeur économique de la superficie occupée aux fins de l'exploitation d'une entreprise selon les circonstances particulières d'une situation donnée. ...

Les parties ont convenu que la somme de XXXXXXXXXX $ par mois proviendrait des revenus nets de location d'un immeuble transféré entièrement à Madame en considération de la dissolution du mariage. ...

Generally speaking and as discussed in Interpretation Bulletin IT-405, Inadequate Considerations- Acquisitions and Dispositions, the rules address transactions that do not occur at fair market value and ensure, amongst other things, that the transferor of property does not artificially reduce the proceeds of disposition and the transferee does not inflate the cost of acquisition. ...

Principal Issues: Whether, in a particular situation where a corporation ("USCO") grants to another corporation ("CANCO") options to purchase additional shares of USCO's capital stock and such options are not granted in consideration for services previously rendered, subsection 15(1) would apply to CANCO at the time of the granting of such options and/or at the time of their exercise. ...

The premium paid on the purchase of a bond is added to its ACB, and any amount deducted under ss. 20(14) of the Act reduces the ACB. (3) The owner of a strip bond is required to include the interest that accrued at the end of the anniversary day of the contract (ss. 12(4) of the Act) and that amount is included in the ACB of the bond (ss. 52(1) of the Act. (4) An estate may deduct the amounts payable to a beneficiary and the appropriate T3 or NR4 slips have to be issued. (5) Various considerations. ...

It is a question of fact as to whether the children would be considered to meet the excluded business test with consideration given to the nature, and the labour requirements of Investco’s business. ...

Additional Information To the best of your knowledge and the knowledge of the taxpayers involved, none of the issues under consideration in this request for an advance income tax ruling: is in an earlier return filed by any of the taxpayers or a related person; is being considered by a tax services office or taxation centre in connection with a previously filed return of any of the taxpayers or a related person; is under objection by any of the taxpayers or a related person; is before the courts in respect of any of the taxpayers or a related person; or is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate to any of the taxpayers or a related person. ...