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As the FMV and adjusted cost base of each class of shares of the capital stock of the corporation would be identical, the same amount of safe income on hand could reasonably be considered to contribute to the capital gain that could be realized on a disposition at FMV, immediately before the dividend, of the share on which the dividend would be received (the capital gain being the same for each class held by each taxpayer). 2. ...

For this purpose, a secondary residence consisting of a building and land, which would be a personal-use property and thus, for tax purposes, one and the same property, could be replaced by a new property, which would also consist of a building and land, and which would be considered as a single replacement property. ...

The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization (it is not the residency of the individual directors that is relevant, but the location at which major organizational decisions are made). ...

Where the relevant preceding taxation year of the taxpayer is also a functional currency year, the taxpayer's first instalment base is based on the amount the taxpayer was required to pay in respect of the preceding year, in Canadian dollars, on account of the taxes payable by the taxpayer under the relevant parts of the Act. 4 More generally, in determining the taxpayer's first instalment base for a taxation year following a particular functional currency year (or the second instalment base for the year after that year), the total of the taxes payable by the taxpayer under the relevant parts of the Act are considered to be equal the total of the Canadian dollar amounts that the taxpayer was required to pay on account of those taxes in respect of the particular taxation year. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax Unedited CRA Tags 85(1); 85(1.1); 220(4.5) Principal Issues: In a given situation, whether (1) a partnership interest could be considered an eligible property under subsection 85(1.1)? ...

Other Comments The application of the Offshore Articles of the relevant tax treaties and the general anti-avoidance rule ("GAAR") may be considered in the type of situation you describe. ...

Any dividend paid by the payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...

You have referred to technical interpretation # 2000-0050975, which considered the Part XIII implications arising from certain risk mitigation payments made under a swap agreement. ...

However, the gift for perpetuity of a conservation easement, that qualifies as an ecological gift, as defined in the Act, by the owner of land is generally considered to be a disposition of part of real property situated in Canada. ...

A determination by Transmission that particular costs are required to be incurred by a Generator in order to permit interconnection with the provincial transmission system is a factor to be considered in determining whether such costs were incurred for the purpose of making a service connection to the project for the transmission of electricity to a purchaser thereof as required by paragraph 1219(1)(a) of the Regulations. ...