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For the purposes of paragraph 149(1)(d.5) and subsection 149(1.2) of the Act, subsection 149(1.3) of the Act provides that 90% of the capital of a corporation that has issued share capital will not be considered to be owned by one or more municipalities unless the municipalities are also entitled to at least 90% of the votes that would be cast under all circumstances at an annual meeting of shareholders of the corporation (see our document # 2001-0114125). ...

In respect of the situation you described, there are two issues to consider, namely whether an "audio book" is a "book" for the purpose of class 12(a) and whether the Taxpayer's stock of audio books can be considered to be a "lending library". ...

The transfer of ownership to the charity is considered to be the disposition of a capital property under subsection 39(1). ...

Any proposed changes to tax policy or amendments to legislation would have to be considered by the Minister of Finance and approved by Parliament. ...

In that letter, you asked us if a Barbados "qualifying insurance company" that is a controlled foreign affiliate of a Canadian resident corporation would be considered to be resident in Barbados for the purposes of Part LIX of the Income Tax Regulations ("Regulations"). ...

The amount of the deferred purchase price would be considered as a separate property and any further recovery or loss would be recognized when amounts were received from the collateralized security entity. ...

However, we have considered your situation and will provide the general comments set out below for your guidance. ...

As a general guideline, if an employee is required to use his or her automobile 3 or more days on a weekly basis for employment-related travel and requires a parking space for this purpose, the parking space would be considered to be used regularly for employment-related reasons. ...

These rules recognize that, generally, transactions between a corporation and its shareholders are considered to be non-arm's length transactions and stipulate that, unless expressly provided otherwise in the Act, transfers of property from a shareholder to a corporation or from a corporation to a shareholder must take place at fair market value. ...

However, we have also considered the circumstance where, all other facts remaining the same, the convertible property (common shares) has a nominal value. ...