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(version anglaise) 22. (1) Paragraph 53(1)(b) of the Act is replaced by the following: (b) where the property is a share of the capital stock of a corporation resident in Canada, the amount, if any, by which (i) the total of all amounts each of which is the amount of a dividend on the share deemed by subsection 84(1) to have been received by the taxpayer before that time exceeds (ii) the portion of the total determined under subparagraph (i) that relates to dividends in respect of which the taxpayer was permitted a deduction under subsection 112(1) in computing the taxpayer's taxable income, except any portion of the dividend that, if paid as a separate dividend, would not be subject to subsection 55(2) because the capital gain referred to in that subsection could reasonably be considered not to be attributable to anything other than income earned or realized by any corporation after 1971 and before the safe-income determination time for the transaction or event or series of transactions or events as part of which the dividend was received. ...

If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. ...

For example, if the adjusted cost base is equal to the fair market value of the preferred shares immediately before the payment of the dividend, there would be no safe income on hand that can be reasonably considered to contribute to the hypothetical capital gain with respect to the preferred shares. ...

The comments in this paper on stock options, stock dividends, and stock splits should also be considered. ...

These elements should be considered in examining the purpose of section 84.1. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue.  ...

(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? ...

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. ...

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress (WIP) and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...

PAYMENTS TO A FORMER PARTNER IN RESPECT OF GOODWILL AND WORK IN PROGRESS Work in progress and goodwill, like other properties of a partnership, are considered to be owned by the partnership for tax purposes. ...