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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. ...