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(ii) Second condition We are of the view that the second condition for the application of section 84(2) would be satisfied since the sale of the assets of Watch4Net, represented primarily in terms of value by the sale of the intellectual property, should be considered to result in the winding-up or discontinuance of the business of Watch4Net. ... They considered that the property acquired by the Tremblay family was different, in its legal form, than the property that was held by the corporation before the transaction, although the economic terms were substantially the same and consequently, subsection 84(2) could not apply. ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income (…) However, it is the CRA's view that the strict and literal approach to the interpretation of subsection 84(2) adopted by the Federal Court of Appeal in Vaillancourt-Tremblay has clearly been rejected by that same court in MacDonald. ...

Accordingly, the advertising service was considered to be performed in part in Canada with the result that it was deemed under s. 142(1)(g) to be a supply made in Canada. ...

.- Q.26-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (d) Where a well that originally was drilled in 1988 is re-entered in 1993 and drilled to a deeper zone resulting in the discovery of a new pool, well recompletion costs related to the portion of the well that was drilled in 1993, the portion of the well that had been drilled in 1988 and the level where production was taken prior to discovery of the new reserves, would be considered to be CEE. ...

93 CPTJ- Q.5-- summary under Paragraph 12(1)(r) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(r) The word "obsolescence" in s. 12(1)(r) is considered to refer to an amount respecting obsolescence of fixed assets where such amount is included as overhead in computing the value of the taxpayer's closing inventory for financial statement purposes, and does not refer to an amount deducted for obsolete goods that themselves form part of inventory. ...

IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa" 16 September 19864-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The allocation of the cost of real estate to inventory in the taxpayer's accounting records will be considered to represent prima facie evidence that the real estate was initially acquired with the intention of reselling it at a profit at a propitious time. ...

4 June 1993 Memorandum (Tax Window, No. 32, p. 9, ¶2602)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee is dismissed, receives an arbitration award and is reinstated to his former position, any amounts received as part of the settlement which are in respect of out-of-pocket expenses incurred by the individual will be considered to be a taxable benefit. ...

As the sites could not be considered to be accessible and serviced throughout the year, the park was not a residential trailer park. ...

"Part I.3 Tax- Deferred Revenue")-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Generally, where an amount of expenses is paid before it is due by one corporation to another corporation that is not a "financial institution", and reported on the annual financial statements as a deferred charge it will be considered to be an advance pursuant to s. 181.2(4)(b). ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Subsection 214(7) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(7) convertible premium taints all other interest The amount considered to be repaid on the conversion of a convertible debenture generally will be the stated capital of the shares issued. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Section 28 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 28 Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed at the convention centre where the gala takes place). ...