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Repairs or Running Expense If a particular software program is only restored to its original condition so that it performs the same applications but the problems of the millennium bug have been eliminated, the expenditures incurred to eliminate the bug would normally be considered to be of a current nature". ...

26 November 1992 Memorandum (Tax Window, No. 27, p. 13, ¶2351)-- summary under Paragraph 55(3)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(b) RC's position that property received by a corporation on a winding-up of a partnership prior to the butterfly reorganization will not nullify the application of s. 55(3)(b) is not considered to be inconsistent with its position that a foreign corporation whose shares are owned by a corporate partnership is a foreign affiliate of the partnership and not of the corporate partners. ...

November 1991 Memorandum (Tax Window, No. 13, p. 14, ¶1584)-- summary under Income of the Corporation for the Year From an Active Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Income of the Corporation for the Year From an Active Business Funds which a CCPC raises by issuing flow-through shares which require the funds to be expended within 24 months on CEE, etc. will be considered to be used in an active business while invested in short-term deposits. ...

Income Tax Technical News, No. 9, 10 February 1997-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) loss transfer must be to affiliated person- related not enough As a result of an amendment to s. 69(11), "a series of transactions that results in the transfer of the benefit of the losses, deductions or other amounts from one corporation to a corporation with which it is not affiliated will generally be considered to result in an abuse.... ...

7 February 1992 Memorandum (Tax Window, No. 16, p. 14, ¶1737)-- summary under Paragraph 60(j.1) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(j.1) Where an individual worked for Oldco for a number of years, Oldco then went out of business and was wound up and the individual then formed Newco which was in the same business as Oldco, Oldco would not be considered to be related to Newco for purposes of s. 60(j.1). ...

.- Q.82-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 Remuneration from a corporation to its principal shareholder-manager and to employees other than his family will not generally be considered excessive where it is the practice to distribute corporate profits to shareholder-employees or employees or where corporate policy is to recompense the shareholder-manager(s) for corporate profits that are attributable to his special contribution. ...

Assuming that it is an avoidance transaction, it would be considered to be a misuse of s. 212(1)(b)(vii). ...

Assuming that it is an avoidance transaction, it would be considered to be a misuse of s. 212(1)(b)(vii). ...

Round Table, Q. 22-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Assets which "are not directly used in the active business carried on by the corporation because of unfavourable market conditions could nevertheless be considered to be 'used principally' for the purpose of the definition of small business corporation, if it is clear that the discontinuance is only temporary and the company intends to use these assets in its business soon". ...

The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest but only to the extent such consideration is not paid for the actual use of the underlying property. ...