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The position, therefore, provides alternatives, rather than restrictions, in the calculation of an allowance for purposes of subsection 81(3) of the Act, by taking into consideration the provisions of provincial Municipal Acts and local by-laws. ...

La société (« Cie A ») dispose d’un bien locatif, au sens du paragraphe 1100(14) du Règlement, en faveur de sa filiale (la « Cie B ») pour une considération correspondant à la juste valeur marchande (JVM) dudit bien soit, 5 000 000 $. ...

The above rulings, which are based on the Act in its present form and does not take into consideration any proposed amendments thereto, are given subject to the general limitations and qualifications set out in Information Circular 70-6R3 dated December 30 1996, and are binding on Revenue Canada provided that the proposed transactions are completed within six months of the date of this letter. ...

These rulings are based on the Act in its present form and do not take into consideration any proposed amendments to the Act. ...

As consideration, XXXXXXXXXX Holdco will either pay cash or issue a note that is not convertible into other property. ...

It nevertheless remains an important consideration in establishing as accurately as possible a picture of profit. ...

The other 70% of the interests in Partnership were held by persons who deal at arm's length with Canco, FA1 and FA2. 3) In year 4, FA2 purchased the other 70% of the interests in Partnership for fair market value consideration. ...

The above ruling, which is based on the Act in its present form and does not take into consideration any proposed amendments thereto, is given subject to the general limitations and qualifications set out in Information Circular 70-6R3 dated December 30, 1996, and is binding on Revenue Canada provided that the proposed transactions are completed within six months of the date of this letter. ...

With respect to the amalgamation of Transferee2 and Subco3 described in paragraph 35A above: (a) the provisions of subsection 87(1) will apply; and (b) subsection 87(1.1) will, for the purposes of paragraph 87(1)(c) and the Income Tax Application Rules, deem the Transferee2 Common Shares to be NewTransferee2 Common Shares received by the shareholder as consideration for the disposition of the Transferee2 Common Shares. 18. ...

This determination required a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...