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Assuming that it is an avoidance transaction, it would be considered to be a misuse of s. 212(1)(b)(vii). ...

Round Table, Q. 22-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Assets which "are not directly used in the active business carried on by the corporation because of unfavourable market conditions could nevertheless be considered to be 'used principally' for the purpose of the definition of small business corporation, if it is clear that the discontinuance is only temporary and the company intends to use these assets in its business soon". ...

The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest but only to the extent such consideration is not paid for the actual use of the underlying property. ...

.- Q. 45-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Generally, loans to employees who are not shareholders of the corporation, to acquire shares, a house, or an automobile, will be considered to be assets used in the active business of the corporation. ...

September 1994)-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) A payment made, or a credit made to a partner's 'capital' account, in consideration of its commitment to perform work for the partnership will be considered to be business income for the partner. ...

.- Q.18-- summary under Term Preferred Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Term Preferred Share In determining whether an issuer of a share is controlled by a specified financial institution either alone or together with any other specified financial institution for purposes of paragraph (b), one of the factors to be considered is whether such specified financial institutions have sufficient common connections or business interests. ...

.- Q.16-- summary under Paragraph 256(7)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a) Where two brothers (A and B) each own 50% of the voting shares of Opco and the shares of Opco owned by B are converted into non-voting shares, A will be considered to have acquired control of Opco. ...

27 March 2000 HQ Letter RITS No. 7940-- summary under Taxable Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Taxable Supply Where an individual who sells the shares of a company to an unrelated third party also receives consideration for a non-compete covenant, the non-compete payment would be considered to be consideration for a supply made by the individual, but would not qualify as a taxable supply because the individual would not be engaged in commercial activity. ...

8 October 2004 Headquarter Letter RITS 53429-- summary under Paragraph 142(1)(g) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(1)- Paragraph 142(1)(g) The supply of advertising space sold in the Canadian edition of a magazine would be considered to be a supply made in Canada as the magazines were circulated in part to newsstands and subscribers in Canada. ...

Events that are the consequence of an act by persons not party to the agreement, e.g. regulatory bodies, can't be considered an event of default. ...