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30 November 1996 Ruling 9702653- PARTITIONING SHARES HELD BY PARTNERSHIP-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition no disposition on partition of shares Where, after a partnership holding shares has been dissolved in compliance with s. 98(3), each former partner surrenders an undivided interest in each of its shares and receives a certificate representing ownership of an equivalent number of whole shares, the partition process will not be considered to constitute a disposition. ...

Accordingly, the method chosen by the taxpayer to follow through on its voluntary offer to redeem debentures did not cause it to be considered to be obligated to redeem the debentures within five years of the date of their original issue. ...

2003 Ruling 2002-0165513- LEASE OF SENIORS RESIDENCE-- summary under Paragraph 149.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(2)- Paragraph 149.1(2)(a) The leasing by a charitable organization of a housing complex to a society (with overlapping directors) who operate and manage the complex as a residence for seniors would not cause the charitable organization to be considered to be carrying on business given that the lease was a net lease and the society would be solely responsible for operating, repairing and maintaining the complex without the benefit of any additional services from the charitable organization. ...

.-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) exercise price respected as the proceeds of property subject to NAL option Although the issue is not referred to, the disposition of property by a corporation pursuant to the exercise of an option by a partnership of which the corporation was a general partner was considered to give rise to proceeds of disposition equal to the exercise price rather than the fair market value of the property. ...

1999 Ruling 9918323- XXXXXXXXXX Business of a Commercial Trust-- summary under Paragraph 206(1)(h) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1)(h) notes of subsidiary unit trust of MFT were not foreign property- so that MFT's units also not foreign property Mutual fund units would not be considered to be foreign property given that more than 80% of the fund's property (in terms of cost amount) was invested in interest-bearing promissory notes of a "subsidiary" unit trust ("CT") with a 25-year term, with the balance of its assets as units of CT. ...

2022 Ruling 2022-0937661R3 F- 104(4) and pipeline transaction-- summary under Subsection 245(2) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(2) GAAR treated as self-applying The Directorate considered that a distribution of the property of a trust under s. 107(2) before its 21 st anniversary to a corporate beneficiary held by a newly-formed trust was an abuse of s. 104(5.8) and ruled that all the property held by the new trust would be deemed to be disposed of at FMV on such 21 st anniversary. ...

25 February 2005 Ruling Case No. 56925 [discount not a device]-- summary under Coupon Summary Under Tax Topics- Excise Tax Act- Section 181- Subsection 181(1)- Coupon discount not a device An electronic discount made available by the manufacturer to all purchasers of the particular product from the retailer would not be considered to be a coupon, as the purchasers would not be in possession of any device that entitled them to a price reduction, and the retailer would not be accepting any device in full or partial consideration for the supply made by it. ...

Ruling On its conversion into DC, BV will not be considered to have disposed of any of its property for the purposes of the Act. ...

CRA stated: Where a member of a partnership acquires or imports property or services related to the raising of funds, negotiation or legal services that the member will use to acquire or maintain an interest in a partnership, such property or services will not be considered to have been acquired or imported for consumption, use or supply in the course of activities of the partnership. ...

The shares of Target will be considered to be "the property" for purposes of s. 95(2)(a)(ii)(D)(III). ...