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In your letter under reference, you state that in responding to an identical hypothetical situation in the technical interpretation, the Department expressed the opinion that subsection 110.6(8) of the Act would not apply, presumably because it considered that no significant part of the capital gain could reasonably be attributable to the fact that dividends were not paid on non-prescribed shares. ...

Thus only those entities which are legally municipalities can be considered to be municipalities. ...

In addition, this matter was also considered in the course of the Departments review of the above referenced interpretation bulletin which review culminated in the release of Interpretation Bulletin IT-463R dated July 12, 1991. ...

If the designation in paragraph 85(1)(e.1) only included properties that were the subject of an 85(1) election, one would still need to know, for purposes of paragraph 85(1)(e), whether properties that were disposed of at the same time but which were not subject to an 85(1) election, should be considered to be disposed of before, after or in between the properties that were the subject of an 85(1) election. ...

The various magnetic tutor tapes and documentation manuals making up the system are considered to be literary works that are subject to copyright protection. ...

The dividend would be deemed to be received under subsection 84(3) of the Act, and accordingly in applying subsection 55(2) of the Act to the dividend, it is only the results of the dividend, and not the purposes of the dividend, which must be considered. ...

However, we would draw your attention to the comments in paragraph 6 of Interpretation Bulletin IT-361, according to which a new evidence of indebtedness is considered to be issued when an obligation is renegotiated otherwise than as provided for under the terms of the original obligation. ...

However, we would draw your attention to the comments in paragraph 6 of Interpretation Bulletin IT-361, according to which a new evidence of indebtedness is considered to be issued when an obligation is renegotiated otherwise than as provided for under the terms of the original obligation. ...

Since the wording in paragraph 3 of Article XII of the Convention may be considered ambiguous, the fact that both the Technical Explanation and Provincial and International Relations Division indicate that the intention was to provide an exemption for the right to tax royalties paid to a U.S. owner with respect to video cassettes for private (home) use, we agreed to interpret the Article in the manner that was in line with the intention. ...

The cash paid for the option could, for the purposes of paragraph 85.1(2)(d) of the Act, be considered to be consideration received for the option and not for the shares of Opco. ...