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No. 1, p. 9, ¶1000)-- summary under Section 206.1 Summary Under Tax Topics- Income Tax Act- Section 206.1 The holder of an exchangeable debenture who exercise the right of exchange will be considered to have acquired the underlying shares for consideration equal to their fair market value. ...

9 February 1990 Memorandum (July 1990 Access Letter, ¶1313)-- summary under Paragraph 8(1)(h) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h) Tree planters who report to several job sites in the course of the year and who cannot be considered to regularly or ordinarily report to any one place of business of the employer, can clearly meet the "in different places" requirement. ...

.- Q.8-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) A genuine loan to a trust, or the unpaid purchase price for a property on an unconditional bona fide sale, will not by itself be considered to result in property being held by the trust on the conditions set out in s. 75(2)(a) and (b). ...

.- Q.6-- summary under Subsection 96(2.1) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.1) Advance income tax rulings will not be provided where one of the main reasons for the arrangement can reasonably be considered to be to circumvent the at-risk rules. ...

Repairs or Running Expense Delay lease rentals are considered to be payments on account of capital and are a cost of a resource property. ...

93 CPTJ- Q.14-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Where a transaction is structured to avoid the application of a specific anti-avoidance rule, the general anti-avoidance rule may still be applicable if it may reasonably be considered that the transaction results in a misuse or abuse of the provisions of the Act. ...

P-061 "Extension of Transferred Payment Policy" B-067 "Goods and Services Tax Treatment of Grants and Subsidies"-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Discussion of the circumstances in which a transfer payment is considered to be the consideration for a supply. ...

Income Tax Technical News, No. 16, 18 December 1998-- summary under Paragraph 55(3.1)(a) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(a) discussion whether Parthenon would indicate that a distributing corporation would not be considered to control its subsidiaries if ultimate control was elsewhere. ...

93 C.M.TC- Q. 12-- summary under Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Affiliate The limited liability companies for the two states that RC has reviewed (Wyoming and Florida) are considered to be corporations rather than partnerships. ...

RC4082 "GST/HST Information for Charities" 6 December 2021 p. 14-- summary under Paragraph 1(g) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part V.1- Section 1- Paragraph 1(g) the value of the listed admissions or rights generally are not considered to be significant if they are less than 30% of the cost of the membership. ...