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The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

The interpretation refers to the "separate transactions" theory whereby the foreign currency component of a foreign currency borrowing is considered as a transaction separate from the borrowing itself. ...

All the issued shares of the Corporation, both voting and non-voting, have to be considered, in determining whether the 90% ownership requirement was met. ...

Jurisprudence dealing with resulting trusts has considered situations where there was a gain on the disposition of property where the husband then alleged that he held one-half the property on a resulting trust for his wife. ...

Pursuant to subparagraph 212(1)(c)(ii), Part XIII withholding tax applies to an amount that can reasonably be considered to be a distribution to a non-resident of a capital dividend received by a trust from a corporation resident in Canada. ...

In your view Y's freeze shares are prescribed shares, within the meaning of Regulation 6205(2)(a), because: (a)     the main purpose of the arrangement was to permit some of the increase in the value of the property of Opco to accrue to X's trust; and (b)     Y should be considered not to deal at arm's length with X's trust because X and Y acted in concert to allow estate planning for the benefit of X's trust. ...

"There are, I think, three matters to be considered: a)   The character of the advantage sought and in this its lasting qualities may play a part. b)   The manner in which it is to be used, relied upon or enjoyed, and in this and under the former head recurrence may play its part and, c)   the means adopted to obtain it; that is by providing a periodical reward or outlay to cover its use or enjoyment for periods commensurate with the payment or by making a final provision or payment so as to secure future use or enjoyment. ...

May we suggest that subsections 13(5.2), (5.3) should also be considered in the event of an exercise of the option to purchase.  ...

(footnote 5) Given the similarities between Gabon SCS and Ivory Coast SCS and partnerships in Canada, these SCSs should be considered partnerships for Canadian tax purposes. ...