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Regulation 5901(2)(b) permits a corporation resident in Canada (CRIC) to make an election in respect of a dividend paid by a foreign affiliate of the CRIC such that the dividend will be treated as a reduction to the adjusted cost base of the foreign affiliate shares on which it is paid, rather than as a distribution from the foreign affiliate's surplus pools. Making this \"preacquisition surplus election\" is often perceived as a straightforward, and administratively simple, way for the CRIC to ensure that the dividend does not result in the unwanted, and potentially adverse, distribution of the foreign affiliate's surplus pools. However, as this article points out, it is important that a CRIC undertake a detailed analysis before deciding to make the election, in order to avoid potential exposure to unintended consequences. This article provides an overview of the legislative history of the election and its underlying policy rationale, and describes the limitations of and restrictions on its use. The authors present some conceptual guidelines (along with examples of their application) for identifying certain circumstances in which the making of the election may be particularly favourable or unfavourable. They also compare and contrast this election with the \"qualifying return of capital\" (QROC) election under subsection 90(3), which may be available in some circumstances as an alternative mechanism for achieving a similar result.

Regulation 5901(2)(b) permits a corporation resident in Canada (CRIC) to make an election in respect of a dividend paid by a foreign affiliate of the CRIC such that the dividend will be treated as a reduction to the adjusted cost base of the foreign affiliate shares on which it is paid, rather than as a distribution from the foreign affiliates surplus pools. Making this preacquisition surplus election is often perceived as a straightforward, and administratively simple, way for the CRIC to ensure that the dividend does not result in the unwanted, and potentially adverse, distribution of the foreign affiliates surplus pools. However, as this article points out, it is important that a CRIC undertake a detailed analysis before deciding to make the election, in order to avoid potential exposure to unintended consequences. This article provides an overview of the legislative history of the election and its underlying policy rationale, and describes the limitations of and restrictions on its use. The authors present some conceptual guidelines (along with examples of their application) for identifying certain circumstances in which the making of the election may be particularly favourable or unfavourable. They also compare and contrast this election with the qualifying return of capital (QROC) election under subsection 90(3), which may be available in some circumstances as an alternative mechanism for achieving a similar result.

According to the news release, 28 Seconds will chronicle the fateful aftermath of that late summer evening in August 2009, an evening when everything changed for the Harvard-educated lawyer, politician, and CEO.

Note: .411 words with 21 in optional trim Ontario PC leader Tim Hudak spent Thursday defending himself against allegations his campaign staged a news conference with stand-ins for a concerned parent group to support his promise to make the province's sex offender registry public.

Once you're set up, it's time to play the waiting game. Pick a spot as close as you dare to shoot without disturbing things, and get ready to wait and watch with your camera at the ready. The picture you want may happen in five minutes or in five hours, but at all times you'll need to be attentive and patient. And whether the moment comes or not, you'll have spent some time in nature, hopefully appreciating it in a way you hadn't before.

In the water\" means you'll need a waterproof camera to get your pictures. And just because your camera is labelled waterproof, that doesn't mean it will take clear pictures underwater - a lesson I learned the hard way. Before you buy a waterproof camera and dive in, make sure your camera is dive-ready, meaning it will take clear, sharp, underwater pictures. And if so, taking photos in the water will make you feel a lot like Jacques Cousteau.

One of the simplest mistakes people make when photographing points of interest is getting too close to both subject and landmark. Don't try to cram too much into your frame. The people in your photograph will get jammed together at close range, parts of the landmark will be cut off or blocked, and, if it's a tall landmark, no one will recognize it if you're looking up its nose. So back up!

Put your camera on a tripod. Align it at your most desired angle, then wait and watch, as a scene unfolds in all its order or chaos. Or take your camera off that tripod and do what professional photographers were taught to do: Shoot around it. Put on a wide-angle lens and exaggerate curves and arches, or back way up to find a long-lens angle that contrasts the unique and the mundane. Force yourself to think differently, see differently, and above all, explore.

While everyone who sets out to capture a night scene should have a tripod handy (it's almost always a must), I'm the type that hates carrying one around and will find other means to get the picture. The saving grace trick for this is really no trick at all: It's stability. This means putting your camera on an immoveable surface or bracing it against one. Park benches, logs, lampposts ... Whatever works to keep your camera steady. No tripod? Use what's around you.