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Thus, the CEE incurred in 1987 and 1998 would be available to Subscribers under the old rules only in respect of Earned Shares issued upon exercises of Rights that took place during 1986, this being the time that the new agreement in writing would be considered to have been entered into. ...

., Dissenting, took the view that as the taxpayer had sold the franchise outright, without the reservation of any interst in the property granted, the sale was of different nature from that considered in Spooner's case, and the payments could accordingly not accurately be described as royalties'. ... The Queen, 77 DTC 5244; have been considered and would appear not to impact upon the conclusions delineated above. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...

To the best of your knowledge and that of the taxpayers involved: (i) none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and (ii) none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

Where property is transferred to a corporation in exchange for shares with a par value, the transferor is considered to have realized proceeds equal to the fair,market value of the shares end not their par value. ...