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Similarly, based upon our understanding of the ITRP as described above, it is our preliminary view, subject to consideration of the final arrangements and regulations relating thereto, that "royalty offsets" arising under the ITRP would also constitute "government assistance" within the meaning of 127(9) of the Act. ...

None of the issued shares referred to herein are or will be, at any time during the implementation of the proposed transactions: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); (d) issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii) held on condition that it or property substituted therefor may revert or pass to Profitco or a person to be determined by Profitco; or (e) a share that is issued or acquired as part of a transaction or series of transactions or events of the type described in subsection 112(2.5). 23. ...

None of the shares referred to herein, including the shares to be issued as described in the proposed transactions, are or will be, at any time prior to the completion of the proposed transactions: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii) held on condition that it or property substituted therefor may revert or pass to Profitco or a person to be determined by Profitco. 20. ...

None of the shares referred to herein, including the shares to be issued as described in the proposed transactions, are or will be, at any time prior to the completion of the proposed transactions: (a) the subject of any undertaking that is a guarantee agreement; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii) held on condition that it or property substituted therefor may revert or pass to Profitco or a person to be determined by Profitco. 20. ...

The transfer price is currently estimated to be $XXXXXXXXXX which will be paid with consideration consisting of $XXXXXXXXXX cash and common shares having a fair market value of $XXXXXXXXXX. ...

X in respect of which no consideration will be received by, or will accrue to, him. ...

You also noted that the CICA Handbook, in section 3400, entitled Revenue, at paragraph.03, defines Revenue as: "... the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of an enterprise, normally from the sale of goods, the rendering of services, and the use by others of enterprise resources yielding interest, royalties and dividends. ...

The amount subject to installment payments is determined by whichever of the following methods* gives rise to the least total amount of installments of tax for the year: (a) the total of the taxes payable under Parts I, I.3, VI and VI.1 by the corporation for the year, determined before taking into consideration the "specified future tax consequences", within the meaning thereof in subsection 248(1) of the Act, for the year; (b) the corporation's first installment base for the year; or (c) the corporation's second installment base and its first installment base for the year. ...

Subsection 14(1) of the Act requires a consideration of whether an amount in respect of damage/compensation, had it been paid rather than received by a taxpayer, would be an "eligible capital expenditure" (i.e., the mirror principle). ...

Accordingly, should you require any assistance with respect to any particular plan, you should provide the details of the plan to the appropriate tax services office for their consideration. ...