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/The transaction will be considered of a capital nature and the capital gain if any, will depend on the proceeds of disposition. ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; d. before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and e. the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this Ruling are the same as, or substantially similar to, transactions and/or issues that are: a) in a previously filed tax return of the Taxpayers or a person related to the Taxpayers; b) being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c) under objection by the Taxpayers or a person related to the Taxpayers; d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate in connection with the Taxpayers or a person related to the Taxpayers. ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; d. before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and e. the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

Pursuant to paragraph 118.2(2)(a) of Act, an amount paid to a medical practitioner, dentist or nurse, or a public or licensed private hospital is considered to qualify as a medical expense of an individual only if it is paid in respect of a medical or dental service. ...

The Court is satisfied that what should be considered here is the use of the space by the Appellant and not the Appellant together with the other co-owners because they had nothing whatsoever to do with the business of the Appellant. (...) ...

The DC Subco common shares and the DC Subco Promissory Note will be considered as cash for all purposes hereof and will be distributed to the parties as cash in the implementation of the transactions described herein. ... Any tax accounts of DC, such as the amount of refundable dividend tax on hand, the balance of any capital dividend account, or any deferred income tax debit balance will not be considered property for purposes of the classification described herein. 34. ... Any tax accounts of DC2, such as the amount of refundable dividend tax on hand, the balance of any capital dividend account, or any deferred income tax debit balance will not be considered property for purposes of the classification described herein. 72. ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is (i) in an earlier return of the above-referenced taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... For the purpose of determining the types of property described herein, (i) the XXXXXXXXXX PubCo class XXXXXXXXXX shares that DC owns will be classified as investment property; and (ii) any tax accounts, such as the balance of any non-capital losses, RDTOH, GRIP or CDA of DC, if any, will not be considered property. ...