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Tips from the Pros on How to Start Your Own Business, 08/30
August 10, 2011 2:55 PM
August 10, 2011
Tips from the Pros on How to Start Your Own Business, August 30th
Challenging economic times do not have to block a dream of starting a successful business, says Paul Bozzo, who is featured as the keynote speaker at a special Sonoma State University Alumni Association networking event on Tuesday, August 30, from 7:30am - 10:00 a.m. at the Sonoma Mountain Business Cluster Event Center in Rohnert Park.
Admission is $5 general public and free to Alumni Association members.
"A sound business idea, the right knowledge, access to community resources and strong determination can lead to a successful start-up," says Bozzo, who will present tips from his "Insider's Guide to Starting and Growing a Successful Small Business." The guide is a review of the most common mistakes entrepreneurs make and how to avoid them as well as the five most important keys for a successful start-up venture.
Bozzo, an expert in business start-up strategies, has more than 20 years of experience in working with entrepreneurial ventures and specializes in strategic business planning and Venture Capital/Angel/Small Business Association funding.
Hard to find resources in Marin and Sonoma County about how to start a business - or grow an existing one - will also be available.
Representatives from a wide range of business and financial concerns will be on hand to address questions in a face-to-face setting so attendees can come away from the event with a clearer sense of how to start their own business or create their own jobs.
Organizations involved include:
- SBDC Santa Rosa JC, NextStep
- North Coast SCORE - Chapter 450
- College of Marin
- Santa Rosa Young Professionals Network
- Sonoma County Economic Development Board
- Exchange Bank SBA Loans
- City of Santa Rosa Economic Development
- Sonoma Mountain Business Cluster/I-Hub
- North Bay Angels
- Sonoma County Alliance
- Chamber of Commerce
- San Rafael
- Santa Rosa
- SBDC: San Rafael
For further information, contact the SSU Alumni Association at 707-664-2426 or e-mail email@example.com.


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With its annual professional awards, the American Society of Landscape Architects puts a bright and prestigious spotlight on groundbreaking garden design. The winners here demonstrate how great designers can bring beauty and sustainability—as well as serenity and functionality—to sites large and small, urban and wild, damaged or pristine.—Bill Marken
To read our full article about the winners, pick up a copy of our November/December 2011 issue, now on newsstands. And for more information about the winners, visit the ASLA's website.
All captions from ASLA and the project winners.
Left: ASLA Award Winner Snake River Residence by Design Workshop, Inc.
Jackson Hole, WY
The reflecting pool appears to drop magically off the terrace into the cottonwood forest. The use of indigenous meadow plants such as little bluestem, combined with native trees and shrubs, helps the designed landscape blend with the exiting natural place.

subset: commoncrawl


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Homemade Gifts | Simple Sewing Projects
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The art of sewing can turn an ordinary object into a custom creation. Regardless of your skill level, we've come up with simple sewing projects that will take your handmade holiday gift up a notch.
Please Note: This article was accurate at the time of publication. When planning a trip, please confirm details by directly contacting any company or establishment you intend to visit.


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YNP Winter Season Beginning Sunday
The winter season gets under way in Yellowstone National Park Sunday, beginning at 7:00 am when visitors will first be able to travel to the park's interior roads this season on commercially-guided snowmobiles or snowcoaches. Spokesman Al Nash says the Geyser Grill, the Bear Den Gift Shop, and the Old Faithful Visitor Education Center at the Old Faithful Area open for the season on Sunday while the Old Faithful Snow Lodge and Cabins and the Obsidian Dining Room open on December 18th. The Mammoth Hot Springs Hotel, dining room and gift shop will open for the season on December 20th. Meanwhile, the Yellowstone General Store, the medical clinic, campground, post office and the Albright Visitor Center at Mammoth Hot Springs are open all year, as are the 24-hour gasoline pumps at Mammoth Hot Springs and Tower Junction. Nash says visitors should come prepared by carrying personal emergency survival equipment and dressing appropriately for outside activities in extremely cold weather.


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The Web Turns a Bullied Boy Into a Hero
While it's always gratifying to see someone get their comeuppance, the video makes us a tad uneasy. It's hard to ignore the fact that Casey is four years older than the bully he takes out, and almost twice his size. Sure, fighting back against constant mocking and physical assaults is an understandable impulse for many of us, but it's hard to call body-slamming a 12-year-old heroic.


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Retro Range 4 peg knitting doll with coloured wool and a wooden needle. Comes with an instruction booklet in a red retro designed box which measures 11cm x 13cm x 3cm. Suitable for children aged 6 years and above.
See what she can do with this cute knitting doll from Retro Range. With helpful instructions and a kit complete with wool, this starter kit is perfect for creative little ones. Keep the doll forever and use it for a myriad of projects such as knitted pin cushions, egg cosies and tablemats. If you like this take a look at the Djeco Children Of The World Sand Set and The Little Experience Stitch-It Dolly for more crafty gifts.
Head to our store to enjoy:
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Mothers of Teenagers Know Why Animals Eat Their Young.Unknown
Raising teenagers is like nailing Jell-o to a tree.Unknown
Teenage girls are too caught up in being with a guy who's the best for everyone else and not the best for themselves.Unknown
A baby-sitter is a teenager acting like an adult while the adults are out acting like teenagers.Unknown
The main problem with teenagers is that they're just like their parents were at their age.Unknown
I don't wait for moods. You accomplish nothing if you do that. Your mind must know it has got to get down to work.Pearl S. Buck
According to Teenage Research Unlimited, 51 percent of 13-15 year olds say they will be faced with making a decision regarding alcohol in the next three months.Xavier Becerra
And out of each (schoolhouse) is vomited the standard product of the New Pedagogy - an endless procession of adolescents who have been taught everything save that which is true, and outfitted with every trick save those that are socially useful.Henry Louis Mencken
Young people on a lark might keep in mind that all birds, except cuckoos, build their nests before hatching their eggs.Unknown
I have always admired the ability to bite off more than one can chew and then chew it.William DeMille
Everyone should see Hollywood once, I think, through the eyes of a teenage girl who has just passed a screen test.Gene Tierney
My eleven year old daughter mopes around the house all day waiting for her breasts to grow.Bill Cosby


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We are totally different and unique!
There have been the great movie palaces - "The Palladium" - "Graumann's Chinese" - "Radio City Music Hall" - even the Drive-ins... Unfortunately, most theaters have evolved into chain-run Octopus-Plexes with row after row of tombstone seats. Instead, experience the Triangle's most beautiful movie theater. Raleighwood.
- Seating at tables in comfortable padded swivel chairs
- Full sized CinemaScope Projection
- Enhanced Dolby Surround Sound
- Casual food, beer, wine and desserts served by our friendly wait staff
- All shows are smoke free
- Afternoon Family Matinees
- Available for Corporate Seminars, Meetings, Parties
- Special Children's Birthday Party Packages
- Special Group Rates for schools groups and senior citizen groups
Raleighwood Cinema Grill is proud to be a local, family-owned and operated theatre.
We strive to provide the very best in movie presentation and food.


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[XML-DEV Mailing List Archive Home] [By Thread] [By Date] [Recent Entries] [Reply To This Message]
Re: External Entites Usage
Pete Johnston wrote: > > > I was a meeting the other day and someone made the following statement. > > > > "External references in entities are highly depreciated and hopefully seldom > > used." > > There was a very useful discussion of this topic on the list a couple > of months ago. You might like to have a look at the list archive ... ... and for the record, despite some strong advocacy on the part of some voices, many of us remained unconvinced. Think of it as a personal style issue. You can abuse any tool, even a chainsaw. Use != abuse. - Dave xml-dev: A list for W3C XML Developers. To post, mailto:xml-dev@i... Archived as: http://www.lists.ic.ac.uk/hypermail/xml-dev/ or CD-ROM/ISBN 981-02-3594-1 Please note: New list subscriptions now closed in preparation for transfer to OASIS.
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As part of our Made Of Manchester celebrations, you may have already read Cliff Butler's piece on the greatest ever Mancunian XI to turn out for United.
But there's no reason to think the list of local legends stops there. Indeed, there are several homegrown talents from the Manchester area currently working their way through the ranks at Carrington.
The Stockport-born twins, Michael and William Keane, have both made first-team appearances (the latter is currently sidelined with a serious knee injury), while Larnell Cole made his bow in last term's League Cup tie at Leeds. Ryan Tunnicliffe came off the bench in the same competition during the 2-1 win against Newcastle earlier this season.
Tyler Blackett appeared on the DHL 2012 tour and is tipped for a bright future and Tom Thorpe captained the Academy team to FA Youth Cup victory in 2011. There are more Manchester-raised prospects out on loan (Reece Brown and Luke Giverin) and further down the age groups, the likes of Kieran O'Hara, Joe Rothwell, Ben Pearson, Donald Love, Joshua Harrop, Ben Barber and Matthew Wilkinson are all hoping to make their mark at OT.


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Chelsea Sexton is one of the country's leading plug-in vehicle advocates. She led protests against GM's decision to scrap thousands of EV-1s, and appeared in the Oscar-nominated film Who Killed...
Electric Executives' Forum - Summer 2001: Are You Ready?
since public awareness is high and people are asking those questions, and we want to take advantage of their interest and make sure we're prepared and ready to do a good job.
Ralph Tedesco
New York State
Electric & Gas Corp.
"We offer our customers very sophisticated meters, whereby they can download usage information over the Internet, and they can use that information to not only manage their usage, but perhaps more intelligently procure supply."
Urging Action from the ISO
NYSEG lays out a plan to keep New Yorkers from paying outrageous electric rates in the coming years.
What prompted you to go public with your warning about problems in New York State's electric market?
I would say there were at least three factors. The key factors were, first, what we saw going on in the wholesale gas and electric marketplace. Secondly was a strong desire to protect our customers and the upstate economy from the volatile, erratic wholesale electric market we have here in New York. And the third thing was a report issued by the New York Independent System Operator that we thought was very unrealistic in its assumptions and therefore flawed.
Things that we've looked at that have caused us some concern were, first, wholesale gas and electric market prices. When we looked at, say, January to January, we saw that the wholesale gas prices were up about 200 percent and in New York wholesale electric prices in that same timeframe were up roughly 100 percent. In addition to that, we feel that there are serious gaps in energy and infrastructure planning in New York, and this will take many years to correct. Other things that we looked at that were going on around us were, in the city of New York, Con Edison customers experiencing 30 to 70 percent price increases. Now Niagara Mohawk is talking about 6 to 10 percent price increases if their merger does not go forward. We have the New York Independent System Operator, contrary to their initial report, now saying that they expect wholesale prices to rise steeply by 2005, as much as 46 percent. And we see in Massachusetts, the Boston Globe is reporting electric price hikes of up to 69 percent.
Setting aside what's going on in California, and collectively, we looked at these things and said that we have a responsibility to protect our customers and, again, to protect the upstate economy from these very volatile price swings. [In upstate New York,] the economy is just now beginning to perk up, and a key part of sustaining that is providing our customers stable prices. And indeed, our customers are in strong support of stable prices and what we call our Price Protection Plan, whereby we are offering to freeze electric prices until 2008. ... [Prices already have been frozen since 1995.] I should also mention that during that same period, our industrial rates have declined 20 percent, and under our Price Protection Plan, we're offering to reduce those industrial rates an additional 5 percent. And this, again, is what


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All News & Blogs
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The Deal: HHH
Visit the Photo Place
Click here to send us a nomination for The Deal
By Craig Schulin
EDUCATION: Mary Washington College, Germanna Community College, graduated from Strayer University
FIRST JOB: My first job was working at the movie theater in the Spotsylvania Mall. I would take tickets, clean theaters and sell movie tickets and popcorn. The job was fun. I watched all the new movies for free and made friends I still talk to today.
WHAT DID YOU WANT TO BE WHEN YOU GREW UP? I always wanted to work with computers. My family bought a Commodore 64 computer when I was 12 years old. My brother and I would make simple programs, play games and talk to people on local bulletin boards.
HOW DID YOU END UP OWNING HEART AND SOUL COMPUTER? I decided back in 2006 that I wanted to start my own computer repair business. I registered the Heart and Soul Computer name with the state of Virginia. I did not have the capital to start the business. I was hired by Computer Sciences Corp. in 2007 and I put 18 percent of my salary into a 401(k) retirement program. I left Computer Sciences Corp. to start the business, and I used the 401(k) funds to finance the operation.
WHAT IS THE BIGGEST CHALLENGE YOU'RE WRESTLING WITH NOW? The biggest challenge is inventory. I do not have the funds to purchase computers, and the selection I offer is limited to three or four different computer systems.
WHAT IS ONE THING YOU WOULD CHANGE ABOUT YOUR JOB? Nothing. I love the job and I really enjoy helping people with computer problems.
WHO WAS AND IS YOUR HERO? I was a huge fan of Dan Marino from the Miami Dolphins. He kept his cool under pressure and delivered great passes under pressure. As I grew older I realized my father is also a great role model. He goes out of his way to help people, and that is a great example to follow.
To nominate a business owner for The Deal, email: DealMaker@free
Provide a description of the business, how long it's operated, its location, contact information, website and why the owner should be featured.


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Breaking News From Todd & Mary
Breaking news from Todd & Mary Brooks…
July 1, 2012 we started our 18th Pilots N Paws Rescue at (KHSV) Huntsville Airport in Alabama, our home base. The weather was HOT (+100), and the day started out with an expired badge. That required some fast coordination to be able to get to our airplane. Then we had a dead battery, so one of the linemen had to jump start our airplane. Once the airplane started we taxied out for takeoff.
Waiting for our clearance we heard over the radio the tail number of the folks we were to meet in Decatur, AL to pick up our first rescue. So, we made a 180 turn around and headed back to the terminal. We met up with Nancy Swanner who had Haliee, a 6-month old, black and white English pointer. Haliee started her rescue trip early in the morning; she started from Mobile, AL where she was driven to Montgomery. From Montgomery, she flew to Huntsville to meet up with us.
We loaded Haliee and an ice pack to keep her cool. Ready for takeoff, but we had another dead battery in all this heat. The poor lineman had to hurriedly jump start our airplane – again. After all of the problems and confusion, we headed to Frankfurt Capital City Airport (KFFT) in Kentucky to meet Russ Roslewski. We handed off Haliee to Russ. Haliee drank some water then we loaded her in Russ's airplane.
He was in a hurry to get off due to bad weather in Ohio. Haliee was a great passenger. She lay in the back seat and just watched everything going on. About 45 minutes left of the flight, she wanted to ride first class (in my lap). Haliee is a great little dog and will make a great family pet.
At Capital City we met up with Marie Bowden a foster mom. She had fostered CiCi for a couple of months. CiCi is a Great Pyrenees/Lab mix. She weighed about 78 pounds. After a couple of photo shots, CiCi was ready for trip to Mid-South Great Pyrenees Rescue in Cumberland, TN. Andee met us at Dickson Airport (MO2) to receive CiCi. CiCi will be fostered until Thursday, and then she will make the ground trip to New York to meet her forever family.
It is always very emotional for these rescuers to let the dogs go, but they know the animals are headed for a better life. All rescues are complex rescues, but they end up very successful. Another part of a successful rescue is finding someone to take care of our 4 dogs. Thanks to Mathew Mason, who took care of our dogs so we could do this rescue.
We appreciate how hard the volunteers work facilitating constantly changing dogs, destinations, times, pilots, and weather.
Unfortunately many others aren't as lucky, and as you all know, the only answer to this devastating issue is to spay/neuter/rescue. All of these dogs are really sweet, and they deserve to be curled up on the living room floor at night not tossed out like trash.


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November 15, 2010
With an estimated 10 percent to 20 percent uptick in Campus Transit van nighttime ridership this year over last year, Baton Rouge, La.-based Louisiana State University (LSU) is reaching out to students to get more part-time drivers.
With an estimated 10 percent to 20 percent uptick in Campus Transit van nighttime ridership this year over last year, Baton Rouge, La.-based Louisiana State University (LSU) is reaching out to students to get more part-time drivers.
Gary Graham, director of the Office of Parking, Traffic and Transportation, said the office has been putting more emphasis on getting out the word to new students about the nighttime availability of the Campus Transit vans, which has bumped up ridership and prompted the need for more drivers as a result. "[Campus Transit] a very important aspect of what LSU does to promote safety among students," he explained. "Obviously the word is getting out because we have seen an increase in ridership this year."
The Office of Parking, Traffic and Transportation currently employs three students as part-time drivers. The service runs from 5:30 p.m. to 3:00 a.m.
The student driver program was started by students in 1984. In the 1990s the program was turned over to the Office of Parking, Traffic and Transportation and has seen a recent revival after LSU's recent campaign to recruit more student drivers. "We can't hire any more full time people so we're looking to increase our student employment," Graham said. The Office announced the job openings on Facebook and Twitter and put ads on buses.
The student hiring process and training entail about one to two week's worth of training. Students also are required to get a Commercial Drivers License (CDL) and to pass the state driving test in addition to passing the typical background checks required for every employee.
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Factors in Transit Bus Ramp Slope and Wheelchair-Seated Passenger Safety Nearly 3 million U.S. adults are wheelchair or scooter users1, and as the population ages this number is expected to rise. Many wheelchair users rely upon public transportation to access work, medical care, school and social activities.
Mass Transit Capital Planning An overview of the world-class best practices for assessing, prioritizing, and funding capital projects to optimize resources and align with the organization's most critical immediate and long-term goals.
The Benefits of Door-to-Door Service in ADA Complementary Paratransit Many U.S. transit agencies continue to struggle with the quality of ADA service, the costs, and the difficulties encountered in contracting the service, which is the method of choice for a significant majority of agencies. One of the most basic policy decisions an agency must make involves whether to provide door-to-door, or only curb-to-curb service.
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Steam table restaurants may be handy (no pun intended), but I think the quality is mostly crap. This also goes for Kabab King over on 27th & Madison…nice people but gloppy, dried out veggies. And they never, ever have ras mulai, even though it's on the menu…argh!
A better bet in Curry Hill is Masala Bollywood on Lex btw 27th & 28th, or Tiffin Wallah on 28th btw Park Ave S. & Lex. Both have cheap and tasty buffets. Chinese Mirch on Lex & 28th is worth a stop, as well.]]>
I enjoy all your videos and the discourses on food. They are excellent and sometimes mouth watering.
Ken Jackson. Ex-Chef de Cuisine.]]>


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For Printable Version select image.
For highway closure and traveler information, visit www.cotrip.org.
For camping guidelines, visit www.fs.usda.gov/goto/r2/procycling2012.
START TIME: 11:10 a.m.
START LINE: Washington and 11th Streets
START VILLAGE HOURS: 8 a.m. – 7 p.m.
Getting Here
From Denver, take 6th Avenue to 19th Street, just below the "M" on Lookout Mountain, go right on 19th to Ford Street, left on Ford to 12th Street, and left on 12th to Jackson Street. From Boulder, continue onto 6th Avenue from Highway 93 and go to 19th Street. Go left on 19th Street and follow the above directions. Carpooling and use of alternative transportation is highly recommended. Bike parking areas will be available throughout downtown. Please heed all areas marked as no parking, whether designated by temporary or permanent signage.
Moving On
To get from the start to the finish, it is suggested that you follow these directions:
Race Day Events
9 a.m. - 9:30 a.m. Kids Adaptive Dash / Start Line on Washington
Until 7 p.m. Race Party and the Samples in concert / Parfet Park in Start Village
Download: Stage 6 Spectator Guide
Download: Stage 6 Route Map
Download: Stage 6 Start Map
Download: Stage 6 Profile
Download: Stage 6 Timetable
Golden Glass - Colorado Glass Works and Early Coors Bottles
Date: April 22 through Sept. 28
Time: Wednesday through Saturday, 11 a.m. to 4:30 p.m. Sunday, noon to 4:30 p.m.
Location: Golden History Center 923 10th St., Golden
Short description: Rarely seen blown-glass dating to the late 1800s, featuring artifacts made at the Colorado Glass Works plant, which operated in Golden, CO from 1887-1888. Included are rare and highly sought-after bottles that are on loan from Dan Mayo and Glen Preble of the Antique Bottle Collectors of Colorado, and from Richard Gardner. Also on view will be glass novelty canes from the City of Golden Collection, as well as early pharmacy, soda, and Coors beer bottles.
Golden Farmer's Market
Date: Saturdays, June 2 through Oct. 6 (excluding July 28)
Time: 8 a.m. to 1 p.m.
Location: 10th and Illinois streets Next to the library
Short description: Support Colorado farmers and merchants every Saturday in Golden. Golden's award-winning Farmers' Market offers a variety of fresh fruits and veggies, frozen fish and meats, fresh breads, canned condiments and sweets, locally-made wines, plus wonderful pasta and unique cooking ingredients. We even offer restaurant vendors, live music and free horse-drawn carriage rides.


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The kind of town where everyone knows everyone. Consists of a school, a Kroger, The Honey Bear, a few gas stations and a car dealer. Everything else is houses. Although small, contains a few stoplights and a railroad. Swanton also hosts fireworks every fourth of July. Oh, and people like to party in Swanton. A lot.
'Let's get drunk after school with the Swanton kids.'
'But it's only Tuesday!'
'What's your point?'
'But it's only Tuesday!'
'What's your point?'
ayon kay Katelyn F ika-13 ng Hunyo, 2008
The shitiest town in the planet, with only a house of games for entertainment.
Person 1: hey you wanna go to swanton?
Person 2: Fuck NO!!! swanton sucks ballz..
Person: tru dat, tru dat..
Person: tru dat, tru dat..
ayon kay Justin Gowing ika-11 ng Hunyo, 2008


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COLUMBUS, OHIO — FEB. 27, 2014 — Dr. David Koncal of Northfield was recently elected to the position of President of the Ohio Veterinary Medical Association (OVMA). At the Association's annual Midwest Veterinary Conference (MVC), outgoing President Dr. Patricia Haines passed on the gavel of the president to Dr. Koncal.
Archive for Press Releases
Koncal assumes role of president of Ohio VMA; Knapp named Veterinarian of the Year
Public Health Hot Topic: Cache Valley-like virus detected in Ohio sheep flocks
The ADDL has recently seen a group of reproductive failure cases in eight sheep flocks and possibly in a single cattle herd between January 10 – 28, 2014 that have been confirmed by NVSL to be either Cache Valley Virus (CVV) or a closely related Bunyamwera virus. Affected flocks were from 4 counties in eastern and southern Ohio (Morgan, Muskingum, Noble and Perry), 2 flocks in Seneca county and one from northern West Virginia (Ritchie county).
OVMA speaks out against governor's plan to tax veterinary services
COLUMBUS, OHIO – MARCH 6, 2013 – In response to the new state budget bill, Ohio Veterinary Medical Association (OVMA) Executive Director Jack Advent will testify today against the addition of a sales tax to veterinary services. Previously exempt, veterinarians, along with many other service providers, now face charging sales tax to their clients if the bill passes.
Haines steps up as president of Ohio VMA; former Public Health Veterinarian honored
COLUMBUS, OHIO — MARCH 6, 2013 — Dr. Patricia Haines was recently elected to the position of President of the Ohio Veterinary Medical Association (OVMA). At an awards ceremony at OVMA's annual Midwest Veterinary Conference (MVC) in February, Dr. Haines formally accepted the position from outgoing President Dr. Ryan Zimmerman of Fremont.
"I am honored to represent the veterinarians of Ohio as President of the OVMA," Dr. Haines said. "Our profession will be continually called upon to provide leadership and education in the care and treatment of all animals. We must provide responses that are reasoned and responsible to encourage resolution, not conflict."
OVMA's new building offers more space, convenient location
The Ohio Veterinary Medical Association has just purchased a new office building, located north of Columbus in Powell, Ohio. The building will offer expanded space for volunteer activities.
OVMA testifies in support of wild and dangerous animal legislation
COLUMBUS, OHIO − MARCH 22, 2012 – The Ohio Veterinary Medical Association (OVMA) testified yesterday in support of Senate Bill 310, which would regulate the ownership of dangerous and wild animals in Ohio. The OVMA has long advocated that the private ownership of certain species should either be prohibited or significantly restricted, a policy in line with that of the American Veterinary Medical Association.
OVMA names Glauer 2011 Ohio Veterinarian of the Year
COLUMBUS, OHIO — MARCH 1, 2012 — Former State Veterinarian David Glauer was recently recognized with the Ohio Veterinary Medical Association's (OVMA) highest honor, the Veterinarian of the Year Award. This award, presented by OVMA's outgoing President Dr. Linda Lord, recognizes one individual for outstanding contributions, dedication and service to the veterinary profession, the community and the animal kingdom.
OVMA recognizes Winsley, Shriver, Washington for contributions to veterinary medicine
COLUMBUS, OHIO — MARCH 1, 2012 — Three local individuals were recognized by Ohio Veterinary Medical Association's (OVMA) outgoing President Dr. Linda Lord for their contributions to veterinary medicine and the community during awards ceremonies at the annual Midwest Veterinary Conference (MVC), Feb. 23-26.
Zimmerman assumes position as president of state veterinary association
COLUMBUS, OHIO — MARCH 1, 2012 — Fremont veterinarian Ryan Zimmerman was recently elected to the position of President of the Ohio Veterinary Medical Association (OVMA). At an awards ceremony at OVMA's annual Midwest Veterinary Conference in late February, Dr. Zimmerman formally accepted the position from outgoing President Dr. Linda Lord of Columbus.
OVMA's Observer wins silver award in national media contest
Bethesda, MD (Dec. 22, 2011) — The Ohio Veterinary Medical Association has been honored with a Silver Award in the Most Improved Magazine or Journal category of Association TRENDS' 2011 All-Media Contest. It was one of more than 450 entries in the association publications contest.
"We are extremely pleased to be considered one of the country's top association publications," said Communications Director Krysten Pyles. "We have worked diligently to improve The Observer, and it is a great honor to be recognized alongside so many respected state and national associations."


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Buchanan endorses Greg Steube
Date: May 5, 2009
by: The Observer Staff
U.S. Rep Vern Buchanan announced his endorsement of Greg Steube for state representative Monday.
"I am pleased today to endorse Greg Steube for state representative," Buchanan said. "Greg was born and raised in Manatee County and is extremely knowledgeable of the district and the district's issues. He has distinguished himself by serving our country in the military and in Operation Iraqi Freedom. Greg would be a great leader for our area and its people."
Steube is an attorney with the newly formed law firm of Najmy Thompson, P.L. and practices in its Lakewood Ranch office. Steube primarily practices in general civil litigation with an emphasis on business litigation, commercial litigation, probate litigation, family and marital law, intellectual property litigation and military law. He also has experience in dealing in the areas of real estate, land use, governmental, agricultural and environmental law.
"I am pleased and humbled to receive the support of Congressman Vern Buchanan," Steube said. "Congressman Buchanan represents a large majority of the district I hope to represent, and his support will help me better serve the citizens of District 67 if elected."
In addition to Buchanan, Steube has garnered endorsements from incumbent Rep. Ron Reagan, state Sen. Michael Bennett, Rep. Bill Galvano, former state senators Pat Neal and John McKay, Hillsborough County Sheriff David Gee, Sarasota County Sheriff Tom Knight, Manatee County Sheriff Brad Steube, former Manatee County Sheriff Charlie Wells, County Commissioner Donna Hayes, County Commissioner Ron Getman and others.
Steube was born in Bradenton and graduated from Southeast High School in 1996. After obtaining his undergraduate degree he went on to attend law school at the University of Florida and graduated with his law degree in 2003.
While in his last year of law school, Steube enlisted in the U.S. Army in the delayed entry program and after completing the bar exam, reported to basic training. After a year in the infantry, he transferred to the Army JAG Corps, where he completed his last three years of service. In 2006, Steube deployed to Iraq in support of Operation Iraqi Freedom with the 25th Infantry Division.
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Income Tax Act - 81-100 - Section 87
Subsection 87(1)
Envision Credit Union v. The Queen, 2013 DTC 5144 [at 6275], 2013 SCC 48
The taxpayer ("Envision") was formed on the amalgamation under the Credit Union Incorporation Act (B.C.) (the "CUIA") of two credit unions. S. 23(b) thereof provided that "the amalgamated credit union is seized of and holds and possesses all the property ... and is subject to all the debts ... of each amalgamating credit union."
The taxpayer sought to avoid having this qualify as an amalgamation described in s. 87(1) of the Act (which required that all property of the predecessors, other than intercompany shares or debts, become property of the amalgamated corporation). To this end, a beneficial interest in some "surplus" real estate was conveyed to a numbered corporation subsidiary at the exact stipulated time for the amalgamation in the amalgamation agreement.
Rothstein J found that s. 23(b) of the CIUA, which should not be overriden by the amalgamation agreement in light of the obvious intent that amalgamated corporations would be responsible for their predecessors' liabilities, caused the amalgamated corporation (Envision) to be seized of its predecessors' properties, including the surplus properties, at the moment of the amalgamation. As to the resulting effect on the sale agreement for the surplus properties (para. 46):
At the moment of amalgamation, the predecessors ... no longer had separate legal personalities capable of fulfilling the terms of the sale agreements. While they were continued under the CUIA, they continued inside Envision. ... So, despite the fact that the agreements listed [them] as the vendors, at the moment of the amalgamation, the vendor was Envision.
In rejecting a "tracing" approach of the Court of Appeal which, in effect, treated the shares of the numbered company as representing the surplus properties, Rothstein J enunciated (at para. 57) the "basic rule of company law that shareholders do not own the assets of the company."
Guaranty Properties Ltd. v. The Queen, 87 DTC 5124, [1987] 1 CTC 242 (FCTD), reversed 90 DTC 6363 (FCA)
A corporation ("Dixie") amalgamated in 1978 to form Forest Glenn, and Forest Glenn amalgamated in 1980 to form Guaranty Properties. A notice of reassessment which the Minister sent in 1981 in the name of Forest Glenn rather than Guaranty Properties in respect of the 1976 taxation year of Dixie was a nullity. "Pursuant to paragraph 87(1)(b) all of the liabilities of the predecessor corporation, Forest Glenn, immediately before the merger became liabilities of the new corporation, Guaranty Properties, by virtue of the merger. Therefore, after November 28, 1980 liability could no longer be affixed to Forest Glenn for the reassessment of Dixie's 1976 taxation year."
Allendale Mutual Insurance Co. v. The Queen, 73 DTC 5382, [1973] CTC 494 (FCTD)
Three insurance corporations were merged pursuant to a special Rhode Island statute, which provided that the three predecessors were "made and consolidated into" the taxpayer and that the corporate existence of the predecessors was "consolidated into and continued in [the taxpayer] which shall be deemed to be the same corporation as each of the" predecessors. Cattanach J. found that the effect of the statute was to create the taxpayer as a new corporation, with the result that there was a qualifying merger under s. 85I(1) of the pre-1972 Act. S."85I(1) does not contemplate that the predecessor corporations must be extinguished ... the paramount factor is that a new entity must emerge."
It was held that the requirement that the shareholders of the predecessors and the taxpayer be the same was met where there were no shareholders of the predecessors or of the taxpayer.
See Also
University Health Network v. The Queen, [2000] PTR 4181 (Ont S Ct J)
The amalgamation of two incorporated hospitals did not cause them to lose their tax-exempt status under the Retail Sales Tax Act notwithstanding that the act of amalgamation did not specifically state such exemption and instead merely indicated that the amalgamated corporation possessed all the property, rights, privileges and franchises and was subject to all liabilities, contracts, disabilities and debts of the amalgamating corporations.
National Bank of Canada v. B.C. (1990), 48 BCLR (2d) 485 (BCSC)
The Bank Act was found to contemplate that the amalgamation of two banks gave rise to the emergence or creation of a new entity in light inter alia to the reference in the Bank Act to the "creation" of the amalgamated entity. Accordingly, an amalgamated bank did not have an instalment base for purposes of the Corporation Tax Act (B.C.).
Loeb Inc. v. Cooper, Cooper and Cooper (1991), 5 OR (3d) 259 (Ont. Ct., G.D.)
The amalgamation under the provisions of the Canada Business Corporations Act of a tenant did not result in an assignment of the lease. Henry J. accepted (p. 270) the submission:
"that an amalgamation under these provisions does not extinguish the existence of any of the amalgamating corporations or create any new corporation. Instead, all the amalgamating corporations are continued as one corporation."
The Great Western Railway Co. v. Commissioners of Inland Revenue, [1894] 1 Q.B. 507 (C.A.)
The Great Western Railway Act, 1892 (U.K.) provided that the undertakings of two other railway companies should be amalgamated with and form part of the undertaking of the Great Western Railway Company, with the amalgamated companies to be dissolved as from the date of the amalgamation. Before finding that this transaction entailed "a conveyance on sale" of the assets of the two dissolved companies for stamp tax purposes, Kay L.J. stated (p. 514):
"It is said that the true effect of this arrangement was that there was a combination of the two companies; the difficulty that suggests itself at once is, how there can be a combination of two companies one of which is dissolved?"
Administrative Policy
2012 Ruling 2010-0355941R3 [reverse triangular "E" merger - survivor style amalgamation]: Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. Target and Subco are continued as one company. The parent of Subco ("Acquireco") receives one Amalco common share for each of its Subco common shares.
The purpose of having Target survive the merger under the plan of arrangement was to allow for an exchange of Target shares for shares of Acquireco to qualify as a reorganization for US income tax purposes for US shareholders of Target, although at the end of the day the Target shareholders received cash consideration from Acquireco instead.
Rulings that the merger will be considered an amalgamation (within the meaning of s. 87(1)) in the context of s. 87(11) ; and that pursuant to s. 87(2)(a), Amalco will be considered to have acquired each capital property of Target within the meaning of s. 87(11)(b).
2006 Ruling 2006-0178571R3 [amalgamation with parent as survivor] [note - the issue re treatment of survivor merger is dealt with under the "Survivor merger," "Purposes," and "Rulings" headings]:
Parent-group losses/FIRPTA. Parent (a.k.a, Target and, following the merger below, Mergeco) is a CBCA public company. It and various direct Canadian subsidiaries (Opco 4 and Opco 2), as well as subsidiaries of Opco 4 (Opco 5C and Opco 7C) have non-capital or net capital losses). Opco 4 also has indirect US subsidiaries which may be relevant to the FIRPT issue referred to below.
Survivor merger. Under the first CBCA plan of arrangement, Parent, Opco2 and Opco4, and subsidiaries of Opco4 will merge with the same effect "as if the parties were amalgamated under section 184 and 186 of the CBCA, except that the separate legal existence of the Parent will not cease and the Parent will survive the Merger." This "approximates a merger of a parent corporation and its subsidiaries as could be effected under U.S. corporate statutes and this type of U.S. merger transaction is the basis for the short-form amalgamation provisions in the CBCA."
Drop-down to LPs for bump purposes. Mergeco then transfer various business assets to subsidiary limited partnerships utilizing the s. 97(2) election.
Funding of Bidco. An existing indirect non-resident shareholder of Mergeco (Shareholder 2) and a private international firm, an LLC, with no previous connection to the structure (Shareholder 1) jointly fund Bidco (a Canadian Newco), with Bidco also borrowing money, and Bidco will acquire convertible senior notes of Mergeco.
Acquisition of Mergeco by Shareholder 1 and 2 group. Under the second plan of arrangement:
- Bidco will transfer the convertible senior notes to Mergeco for cancellation
- The shareholder rights plan for Megeco will be cancelled
- The outstanding Mergeco options will be cash-surrendered to Mergeco
- Mergeco shares of dissenters will be transferred to Bidco for their fair value
- At the same time, all other Mergeco shares will be transferred to Bidco for cash consideration – except that Mergeco shares held by affiliates of Shareholder 2 will be transferred to Buyco 1 (a joint newly-formed 50/50 subsidiary of Shareholder 1 and 2) in consideration for shares of Buyco 1
- All the shares of Bidco held by the Shareholder 1 and 2 groups will be transferred to Buyco 1 in consideration for shares of Buyco 1, so that Buyco 1 is owned equally by the two groups
- The Mergeco shares held by Buyco 1 will be transferred to Buyco 2 (an affiliate of Shareholder 1) for shares of Buyco 2
- Mergeco will elect to cease to be a public corporation (and also elect under s. 256(9) in its tax return)
- Buyco 2 will transfer the shares of Mergeco to Bidco for shares of Bidco.
S. 88(1)(d) bump. Following the continuance of Bidco under the CBCA, Bidco and Mergeco will amalgamate in a vertical short form amalgamation to continue as Amalco.
Amalco will make a bump designation under s. 88(1)(d).
Purposes. The stated purposes include "(ii) to avoid any US FIRPTA…issue that could arise from the combination of the Parent and of the Subsidiaries, (iii) to consolidate, before the Effective Time [of the 2nd plan of arrangement], the Losses of the various Canadian entities into two corporations…."
Rulings. Ruling that s. 87 will apply to the merger pursuant to the 1st plan of arrangement; and s. 88(1)(d) bump ruling.
3 December 2003 TI 2003-004601: Where a predecessor corporation made a transfer to a partnership described in s. 97(2), the amalgamated corporation can file the s. 97(2) election in respect of the transfer.
10 April 2003 T.I. 2002-016977: Where a Japanese parent merges with his Japanese subsidiary which, in turn, holds shares of a Canadian company, the Japanese subsidiary will not be considered to have disposed of its assets, including the shares of the Canadian company, if the applicable corporate law in Japan is of a "continuation type". However, there may be a disposition of the share in the Japanese parent and subsidiary by the respective shareholders as a result of the merger before taking into account the possible effect of the addition of paragraph (n) to the definition of disposition.
2 February 2000 TI 2000-000338: The tax accounts of predecessor corporations do not flow through to the merged corporation in a non-qualifying amalgamation.
1997 Ruling 3-972405: An amalgamation under which a shareholder of one of the predecessors would be entitled to receive redeemable preferred shares which would be redeemed for cash shortly after the amalgamation, unless it dissented in which case it would receive a cash payment for its shares of the predecessor in accordance with section 190 of the CBCA, would qualify as an amalgamation irrespective whether or not the shareholder exercised its statutory rights of dissent.
12 August 1994 T.I. 5-941549 (C.T.O. "Amalgamation/Wind-up"): Although, on the amalgamation of a wholly-owned subsidiary with its parent where the subsidiary also owns shares of the parent, s. 69(1)(b) would ordinarily apply to deem the subsidiary to have received proceeds of disposition for the shares of the parent equal to their fair market value, para. 42 of IT-474R provides that where one predecessor corporation holds shares of another predecessor corporation, the cancellation of those shares on the amalgamation will not give rise to a gain or loss in the hands of the former corporation.
92 C.R. - Q.26: Where an amalgamation does not qualify under s. 87 and, under the governing corporate law, the amalgamated corporation is considered to be a continuation of its predecessors, the predecessor corporations generally will not be considered to have disposed of any assets held immediately before the amalgamation. However, shareholders of each predecessor generally will be considered to have disposed of their shares for capital gains purposes.
91 C.R. - Q.22: Where a shareholder of a predecessor corporation, who is entitled to only a fraction of a share of the amalgamated corporation, or who dissents to the amalgamation, receives cash, s. 87 will apply to the amalgamation.
89 C.P.T.J. - Q14: Because there is no provision like s. 87(1.2) deeming an amalgamated corporation to be a continuation of each predecessor, where a corporation has issued flow-through shares and amalgamates with another corporation prior to incurring the expenditures, the amalgamated corporation will not be able to renounce expenditures incurred subsequent to the amalgamation, unless the amalgamation was described in s. 87(1.1).
89 C.P.T.J. - Q15: Because Deltona indicates that an amalgamated corporation is incorporated on the amalgamation, a corporation that currently is disqualified as a JEC due to having once had more than 10 shareholders can be cleansed by an amalgamation.
IT-474R "Amalgamations of Canadian Corporations"
Henry Chong, "Surviving North of the Border: Structuring a Statutory Merger in Canada to Qualify as a U.S. Tax-Free Reorganization," Tax Management International Journal, 2012, p. 611: Respecting 2006-0178571R3, he states that the CRA position
appears to be based on the view that the reference in s. 87(2)(a) to "new corporation" referred to the amalgamated corporation, whether it was a continuation of the amalgamating corporation or, in the case of the ruling, a survivor….
Under this approach, s. 87(2)(a) deems a "new" corporation to exist for at least some Canadian tax purposes, regardless of its status under the corporate law. Based on the tax fiction that there is a "new" corporation, all of the assets and liabilities of the predecessor corporation can be said to have "become" the assets of the "new" corporation for tax purposes even if, for non-tax purposes, each corporation arguably continues into the merged corporation and accordingly continues to own or be liable for its assets and liabilities throughout. Based on [this ruling], this fiction would seem to apply equally where one of the corporations survives and continues to own its assets. The survivor would be deemed to be a "new" corporation….
Re 2010-0355941R3, it appears to produce "a reasonable result as there is nothing in the s. 87(2)(a) analysis that would be limited to cases where the parent is the survivor."
Stephen S. Ruby, "Recent Transactions of Interest," 2007 Conference Report (Toronto: Canadian Tax Foundation, 2008), 3:1-41, at 3:13-17: Discussion of the Chesapeake Gold Corporation acquisition of American Gold Capital entailing a "survivor style" merger.
Firoz Ahmad, "Amalgamation Versus Winding-Up Revisited", Canadian Current Tax, Vol. 15, No. 4, January 2005, p. 33.
Richards, "Amalgamations", The Taxation of Corporate Reorganizations, 1996 Canadian Tax Journal, Vol. 44, No. 1, p. 241.
Vesely, "Takeover Bids: Selected Tax, Corporate and Securities Law Considerations", 1991 Conference Report, c. 11.
Schwartz, "Statutory Amalgamations, Arrangements and Continuations: Tax and Corporate Law Considerations", 1991 Conference Report, c. 9.
Williamson, "Checklists: Corporate Reorganizations, Amalgamations (Section 87) and Wind-ups (Subsection 88(1))", 1987 Conference Report, c. 29.
Paragraph 87(2)(a)
CGU Holdings Canada Ltd. v. The Queen, 2009 DTC 5685, 2009 FCA 20
Noël, J.A. rejected a submission of the taxpayer that s. 87(2)(a) deemed an amalgamation of three corporations (one of which was an NRO) to be a new corporation only for purposes of the computation of its income (Division B) and taxable income (Division C). Accordingly, the amalgamated corporation also was a new corporation for purposes of the NRO rules contained in Division F.
The Queen v. Pan Ocean Oil Ltd., 94 DTC 6412 (FCA)
The taxpayer was the result of a 1974 amalgamation of two Alberta corporations, one of which was a second successor corporation for purposes of s. 29(29) of the ITARs respecting exploration and drilling expenses made prior to 1972. Hugessen J.A. held that because the taxpayer was a new corporation for income-computation purposes and was not the second successor corporation, there was no provision of the Act permitting it to deduct oil and gas exploration expenses incurred by other taxpayers. With respect to the effect of the reasons of MacGuigan J.A. in the Guaranty Properties case, he indicated (at p. 6416) that they only established that "the provisions of paragraph 87(2)(a) are applicable only to the amalgamated company's computation of income under Division B (including the 'deductions to which it may be entitled') and, where necessary as a consequence thereof, to its computations of taxable income (Division C) and of tax (Division E)", and that the decision "should not be read as denying that the amalgamated corporation is to be deemed to be a new corporation for all purposes relating to the computation of its income".
The Queen v. Guaranty Properties Ltd., 90 DTC 6363 (FCA)
Following the amalgamation of the two predecessor corporations of the taxpayer under the laws of Ontario, the Minister issued a reassessment and then a notice of confirmation in the name of a predecessor corporation. In rejecting a submission by the taxpayer's counsel that the implication of s. 87(2)(a) was that the predecessor corporation had ceased to exist by virtue of the amalgamation (with the result that the reassessments were invalid) MacGuigan, J.A. stated (p. 6363):
"The principal effect of paragraph 87(2)(a) is that, for income tax purposes, the amalgamated corporation is deemed to be a new taxpayer with a fresh taxation year as of the date of amalgamation. In sum, nothing in the paragraph evinces an intention on the part of Parliament to deem that the amalgamating taxpayer ceases to exist, much less than it should be relieved of liability for its own income taxes prior to the date of amalgamation. That the paragraph, indeed the entire section, deals with the computation of income is also an inference to be drawn from the fact that it falls under Division B of Part I of the Act which deals with the computation of income, as opposed to [Division] A, which is concerned with liability for tax."
See Also
CGU Holdings Canada Ltd. v. The Queen, 2008 DTC 3347, 2008 TCC 167
The taxpayer was formed on the amalgamation of three predecessors, only one of which was a non-resident-owned investment corporation ("NRO"). Subsection 134.1(1) permitted a corporation that had been an NRO in its preceding taxation year to make an election. After referring (at para. 29) to the corporate law that "a predecessor remains in existence", Hershfield J. went on to find (at para. 33) that as s. 134.1 did not deal with the calculation of income or taxable income (as specified in s. 87(2)(a)), the case law was clear that the predecessor NRO had not ceased to exist by virtue of the amalgamation, so that the taxpayer, as a continuation of the NRO predecessor, could make the election in s. 134.1(1).
Administrative Policy
15 April 2014 T.I. 2014-0527231E5 F [same day amalgamation following control acquisition gives rise to two taxation year ends if out-of-normal course transactions occur on day of closing]: A plan of arrangement provides for the following transactions to occur on 18 January 20X1 and in the indicated order but without a particular hour for each transaction being specified:
- Sale of some assets of the corporation.
- Roll of its shares.
- Acquisition of its control (with no s. 256(9) election being made).
- Amalgamation with the acquirer.
After repeating general comments from 2014-0523251E5 F (quoted immediately below), and noting that s. 249(4)(a) deemed there to be a taxation year end immediately before the commencement of January 18, CRA stated (TaxInterpretations translation):
The moment of such taxation year end thus could only be before the effective hour of the transactions occurring before the amalgamation (taking the into account the logic of their ordering). … Therefore, the corporation must account for the tax consequences respecting the asset sale and share rollover transactions (which occurred before the acquisition of control and the amalgamation) in the taxation year of the corporation terminating before the amalgamation.
The corporation thus technically has two taxation years, one which is deemed to end at the end of 17 January 20x1, and the other which would end in the course of January 18… . The second…would be very short.
26 March 2014 T.I. 2014-0523251E5 F [double taxation year ends where transactions occur on the closing date before acquisition and amalgamation]: Following a sale of assets of a corporation and a rollover of its shares on 18 January 20X1, an acquisition of control of the corporation occurs at 18:00 hours and it then is amalgamated with the acquirer. The plan of arrangement or closing agenda, as the case may be, does not specify particular times at which these transactions occur and the corporation elects under s. 256(9) for the acquisition of control to occur at 18:00 hours. Will multiple year ends occur as a result and, if so, in which taxation year will the preliminary transactions be considered to occur?
CRA stated (TaxInterpretations translation):
When a corporation does not effect transactions outside the ordinary course of business on the day of an amalgamation for which the certificate of amalgamation does not specify the hour of the amalgamation, we consider that the amalgamation generally will occur at the beginning of the day… . In contrast, our position is different when a plan of arrangement or a closing agenda provides for various transactions out of the ordinary course of business to occur on the day of the amalgamation in addition to the acquisition of control and the amalgamation… If the transactions are effected...in a logical order...[CRA] will consider that the amalgamation occurs at a moment determined in accordance with the logic of the transactions. … [Here] this moment follows the effective time of the acquisition of control. …
[B]y reason of the subsection 256(9) election, a deemed taxation year end occurs…at the moment immediately before 18:00 hours… .The corporation must take into account the taxation consequences of the sale transactions…and the share rollovers …in the taxation year…which terminated immediately before the effective time of the acquisition of control. …
Furthermore, given that the amalgamation occurs after all the transactions of January 18…, including the acquisition of control…at 18:00 hours, the second taxation year of the corporation terminates immediately before the amalgamation by virtue of paragraph 87(2)(a). …Therefore, the corporation technically has two taxation years which are deemed to end on January 18… . The second…is very short.
2010-0388081E5 [double year ends where acquisition of control under s. 256(7)(b)(ii)]: On the amalgamation of public corporation ("Pubco") and a private corporation ("Holdco") to form Amalco, the three shareholders of Holdco acquire control of Amalco. In finding that this gave rise to two taxation year ends of Pubco, CRA stated:
[O]n the one hand…the taxation year of Pubco would be deemed to have ended immediately before the amalgamation of Pubco and Holdco pursuant to paragraph 87(2)(a)… . On the other hand, the group of three persons originally shareholders of Holdco would be deemed to have acquired, immediately before the amalgamation, control of Pubco pursuant to subparagraph 256(7)(b)(ii) of the ITA. Consequently, and in accordance with paragraph 249(4)(a)…the taxation year of Pubco…would be deemed to have ended immediately before that time. In other words, the deemed acquisition of control of Pubco resulting from the amalgamation would technically generate a deemed taxation year end with respect to Pubco immediately before the time that is immediately before the amalgamation.
2010 STEP Roundtable Q. 3 No. 2010-0388081E5: It is generally CRA's position that a target corporation will only have one deemed year end where an acquisition of control of the target is followed on the same date by its amalgamation with the acquirer. "Furthermore...it would appear to be appropriate generally that the transactions which are legally effected by the predecessor corporation should be reported by that same predecessor corporation for tax purposes, rather than by the amalgamated entity."
Memorandum 7-920752 (January - February 1993 Access Letter, p. 24, ¶C82-109): The Rulings Directorate no longer is providing relief where taxpayers suffer unpredictable and unfavourable consequences pursuant to s. 87(2)(a).
3 July 1991 T.I. (Tax Window, No. 5, p. 13, ¶1334): RC's assessing policies with respect to amalgamations are under review because of the decision in the Guaranty Properties case.
12 December 1989 T.I. (May 1990 Access Letter, ¶1221): Although an amalgamated corporation is a new corporation for the purposes of computing income and tax otherwise payable, s. 87(2)(a) is not relevant in determining entitlement to VCT credits under section 8.3 of the Income Tax Act (B.C.).
MacDonald, "Amalgamations Following Guaranty Properties Limited", 1991 Canadian Tax Journal, p. 1399.
Paragraph 87(2)(b)
Administrative Policy
5 March 1992 T.I. (Tax Window, No. 17, p. 21, ¶1785): Where two or more corporations amalgamate, the cost amount of the inventory of a predecessor corporation is its value determined for the purpose of computing its income for the taxation year which ended immediately before the amalgamation.
27 February 1991 Memorandum (Tax Window, Prelim. No. 3, p. 24, ¶1113): An amalgamated corporation must use the same inventory valuation method as its predecessors. Where an amalgamated corporation has two predecessors with homogeneous inventories and different valuation methods, the amalgamated corporation will be justified in changing its method of valuing inventory in order to avoid distortion in the calculation of profit for accounting purposes.
Subsection 87(2.1)
Administrative Policy
17 June 2003 T.I. 2002-017825: The non-capital losses of a subsidiary which amalgamates with its parent would be available to be applied against a forgiven amount arising on the forgiveness of a commercial debt obligation incurred by the subsidiary before the amalgamation. In particular, s. 87(2.1)(a) would apply to the application of s. 80(3): even though s. 80(3) is in Division B, not Division D, and s. 87(2.1)(a) applies for Division D and not Division B purposes, s. 80(3) applies for the purpose of computing Amalco's taxable income in Division D including a determination of Amalco's non-capital losses.
Subsection 87(2.11)
Administrative Policy
2011 Ruling 2011-0411821R3: a limited partnership ("BForLP") owns substantially all of the membership interests in a (presumably Netherlands) holding cooperative which owns all the shares of a non-resident corporation ("BForHoldco") which holds all of the shares of a taxable Canadian corporation ("BCo") which holds a majority of the voting common shares (Class B shares) of another taxable Canadian corporation ("Opco") with the balance of the common shares (Class A shares) and preferred shares being owned by a taxable Canadian corporation ("ACo") with which BCo deals at arm's length.
BForLP uses the proceeds of a daylight loan to make an interest-bearing loan (the "Sub Debt") to BCo, with BCo using the lent money to distribute paid-up capital (used by BCo for an income-producing purpose) to BForHoldco, and so on up the chain so that BForLP can fund the repayment of its daylight loan. BForHoldco then transfers its B shares to Opco in consideration for the issue of shares of a new class of common shares of Opco (with this "tuck-under" transaction not being ruled on), Aco effects a simultaneous s. 86 exchange of its shares in Opco (so as to preclude the tuck-under transaction giving rise to an acquisition of control of Opco by Aco), and BCo and Opco then amalgamate by way of a vertical short-form amalgamation.
Ruling that s. 87(2.11) will apply to the amalgamation.
22 June 1999 Memorandum 983352: Following a vertical amalgamation, the amalgamated corporation would not be able to carry back ITCs generated by it to reduce Part I tax of the subsidiary.
94 C.P.T.J. - Q.14: S.87(2.11) does not permit the carry-back of non-capital losses of a predecessor subsidiary corporation for utilization by the predecessor parent corporation.
Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Subsection 87 (2.11)": S.87(2.11) does not allow losses of a wholly-owned subsidiary corporation to be applied against the taxable income of its parent for taxation years of the parent prior to the amalgamation.
25 February 1993 T.I. (Tax Window, No. 30, p. 19, ¶2468): S.87(2.11) permits an amalgamated corporation to carry back its non-capital losses to the predecessor parent corporation, but not to the predecessor wholly-owned subsidiary.
1992 A.P.F.F. Annual Conference Q.3 (January - February 1993 Access Letter, p. 51): The purpose of s. 87(2.11) is to make the consequences of a vertical amalgamation similar to those for a winding-up.
Subsection 87(3)
Administrative Policy
80 C.R. - Q.29: RC may not object to the shifting of paid-up capital on an amalgamation if it is satisfied that the shifting is not primarily for the benefit of certain shareholders and the potential tax recovery will not have changed significantly.
Tetreault, "The Application of Subsection 87(3) in an Amalgamation Squeeze-out", Canadian Current Tax, November 1988, p. 41: The CBCA would appear to have provided less flexibility than the OBCA in avoiding a grind under s. 87(3) on an amalgamation squeeze-out.
Subsection 87(4)
Husky Oil Ltd. v. The Queen, 2010 DTC 5089 [at 6887], 2010 FCA 125
In order to accomplish a sale of a subsidiary of the taxpayer on a tax-deferred basis for a purchase price of $15.5 million payable in 25 years' time without interest, the subsidiary was amalgamated with a subsidiary of the purchaser, and the taxpayer received preferred shares which would be redeemable for $15.5 million in 15 years' time. In finding that the "gift portion" rule in s. 87(4) did not apply to deny rollover treatment to the taxpayer, Sharlow, J.A. noted that, as the purchaser dealt at arm's length with the taxpayer, there was no person related to the taxpayer who stood to benefit from the alleged shift in value to the purchaser resulting from the amalgamation, and stated (at para. 58) that this rule was:
"intended to deter a taxpayer from using the device of a corporate amalgamation to shift part or all of the value of a predecessor corporation to the amalgamated corporation if, but only if, a person related to the taxpayer has a direct or indirect interest in the amalgamated corporation that will be enhanced by the shift in value."
Administrative Policy
2002 Ruling 2002-017716: Rights under a shareholder rights plan of Parent received by shareholders of Target on a triangular amalgamation of Target, a subsidiary of Parent and Parent would not constitute "consideration" for purposes of s. 87(4) given that the rights were of little or no value and given that:
"The Amalgamation Agreement will provide that the shares of Parent and Amalco ... will be the sole consideration for the exchange. It will not be a condition to the amalgamation that the Plan be in effect at the time of the amalgamation; instead, Parent will reserve the right to terminate the Plan in accordance with its terms before the amalgamation."
23 February 1999 T.I. 5-983222: The policy in IT-474R, para. 40 (respecting the maintenance of ACB when preferred and common shares of a predecessor are converted into preferred and common shares of the amalgamated corporation) will also generally apply where the amalgamation agreement provides for the conversion of numerous classes of preferred and common shares of the predecessor into numerous classes of preferred and common shares of Amalco.
Handbook on Securities Transactions, 94-110(E): No reporting is required if, during an amalgamation, a shareholder receives cash or some other consideration totalling $200 or less, instead of a fractional interest in shares.
92 C.R. - Q.32: Where a corporation whose shares are owned by an individual amalgamates with a loss company whose shares are held by, and whose loan capital is owed to, a related individual, it is likely that ss.87(4)(c) to (e) will apply in respect of the amalgamation, in which case RC will not seek to apply s. 15(1).
25 August 1992, T.I. 921458 (April 1993 Access Letter, p. 144, C82-113): The position in IT-474R, that s. 87(4) will not be applied where an amalgamation agreement provides that the preferred and common shares of a predecessor corporation are to be converted to preferred shares and common shares of the amalgamated corporation, will also prevail in the case of a short-form amalgamation even though in such instance the conversion takes place pursuant to the governing corporate legislation rather than pursuant to an amalgamation agreement.
Subsection 87(4.3)
See Also
Envision Credit Union v. The Queen, 2010 DTC 1399 [at 4585], 2010 TCC 576
Webb, J. found, in obiter dicta (at para. 89), that an amalgamated corporation resulting from an amalgamation that was not described in s. 87(1) was required to include in its preferred rate amount calculation the preferred rate amount balances of its predecessors, given that it was a continuation of them.
Subsection 87(7)
The Queen v. Dow Chemical Canada Inc., 2008 DTC 6544, 2008 FCA 231
The taxpayer ("Amalco") was formed on the amalgamation of two corporations, one of which ("UCCI") had previously incurred interest-bearing indebtedness to a financing affiliate within the Union Carbide group of companies and the other of which ("DCCI") was a Canadian subsidiary within the Dow group of companies that dealt at arm's length with UCCI and the financing affiliate up to the time of acquisition of control of that group by the Dow group of companies. The interest in question was incurred in the 2000 taxation year of UCCI, the next taxation year of UCCI ended in 2001 with the acquisition of its control by the Dow group, and its next taxation year ended in 2001with its amalgamation.
In finding that s. 78(1) applied to Amalco, Noël, J.A. rejected [at para. 31] the submission of the taxpayer "that Amalco should be viewed as having incurred the obligation back in 2000, but without regard to the non-arm's length relationship that prevailed at that time" after having noted [at para. 30] that under s. 87(7)(d) "an amalgamated corporation stands in the shoes of its predecessor insofar as previously incurred debts are concerned as of the time when they were incurred".
See Also
Dow Chemical Canada Inc. v. The Queen, 2007 DTC 1701 2007 TCC 668
The taxpayer was formed on the amalgamation of two corporations, one of which ("UCCI") had previously incurred interest-bearing indebtedness to a financing affiliate within the Union Carbide group of companies and the other of which ("DCCI") was a Canadian subsidiary within the Dow group of companies that dealt at arm's length with UCCI and the financing affiliate. The U.S. parent of the taxpayer ("Dow") had acquired control of the U.S. parent of UCCI, and the amalgamation then occurred.
Mogan, D.J. found that s. 78(1) did not apply to the interest on such debt as the taxpayer was not related to UCCI or the financing affiliate in fact or by any deeming rule during the calendar year in which such interest was incurred.
Subsection 87(8)
Mark, Thon-That et al., "Cross-Border Reorganizations", International Tax Seminar, IFA, 19 May 1999, c. 6.
R.I. Crosbie, "Canadian Income Tax Issues Relating to Cross-Border Share Exchange Transactions", 1997 Corporate Management Tax Conference Report, c. 12.
Schwartz, "Tax-Free Reorganizations of Foreign Affiliates", 1984 Canadian Tax Journal, November-December 1984, p. 1039.
Subsection 87(8.1)
Administrative Policy
2 June 2003 T.I. 2003-001331: The position on receipt of cash in lieu of fractional shares on an amalgamation that is intended to be governed by s. 87(1), as described in paragraphs 38(b) and 39 of IT-474R, also applies to a foreign merger, as defined in s. 87(8.1).
25 August 2000 T.I. 2000-002624: Confirmation that there was a qualifying "foreign merger" where Canco launches a share-for-share exchange takeover bid to acquire shares of Target (a U.S. corporation) and, following completion of the bid, it carries out one of various described types of mergers with Target, including (in the situation where it has acquired more than 90% of the outstanding shares of Target) causing a new U.S. subsidiary of Canco to be merged into Target with the remaining Target shareholders receiving shares of Canco.
2000 Ruling 2000-002395 amended by 2000-0034951: A vertical merger between a US corporation with a Canadian branch business ("Absorbco") and its US parent ("Subco 3") under which Absorbco survives the merger, the US parent of Subco 3 exchanges its shares of Subco 3 for shares of Absorbco, and the shares of Subco 3 are cancelled, would qualify as a foreign merger. Accordingly, unless the non-resident parent of Subco 3 elects otherwise, ss.87(a) and 87(4) will apply to the non-resident parent.
28 February 2000 1999-001436: A foreign triangular merger qualified as a foreign merger notwithstanding that shareholders of the target would receive shares both of the merged company and the acquisition company.
14 December 1998 T.I. 981130: Where Subco A, Subco B and Parentco are all resident in the U.S. with Subco A being a wholly-owned subsidiary of Parentco, Parentco holding less than 10% of the shares of Subco B and the remainder of Subco B's shares being held by Canco, a merger of Subco A with Subco B as a result of which Subco A is the surviving corporation, with Parentco not receiving any shares of Subco A in exchange for its Subco B shares and Canco receiving shares of the amalgamated corporation in exchange for its shares of Subco B, would be a qualifying foreign merger.
Robert D'Aurelio, "International Issues: A Revenue Canada Perspective," 1990 C.R., p. 44: 13:
...it is the department's view, after giving consideration to the intention of subsections 87(8) and (8.1), that the "new foreign corporation" referred to in those subsections would include the surviving entity of an absorptive merger in the United States. This is a situation in which, on the effective date, every disappearing corporation that is a party to the merger is absorbed by the surviving corporation, and the surviving corporation automatically becomes owner of all real and personal property and becomes subject to all liabilities, actual or contingent, of each disappearing corporation. Such a reorganization will qualify as a "foreign merger" if all or substantially all of the shares of the capital stock of the disappearing corporation and the surviving corporation (except any such shares owned by any of those corporations) are exchanged for or become shares of the capital stock of the surviving corporation (that is, the "new foreign corporation").
84 C.R. - Q.50: Where one or more predecessor corporations continue in the form of one corporate entity, that corporate entity is considered to be a new foreign corporation.
Subsection 87(8.2)
Administrative Policy
4 March 2013 Memorandum 2012-0449371I7:
In 2006, a wholly-owned CFA (FA1) of Canco merged with a wholly-owned subsidiary (FA2) of FA1, with FA2 as the surviving corporation under the corporate law of the foreign jurisdiction (i.e., a downstream merger).
In accordance with the corporate law of that foreign jurisdiction, the shares of FA2 held by FA1 were distributed to Canco and the shares of FA1 were cancelled; all the property held by FA1 immediately before the merger was transferred to FA2 at the time of the merger; and FA1 ceased to exist after the merger.
CRA noted that draft s. 87(8.2) applied to both upstream and downstream mergers, and that there was no implication in the parenthetical exclusion in s. 87(8.1)(c) that the shares of FA2 be cancelled on the merger rather than being distributed to Canco.
As "Canco did receive consideration for its disposition of the shares of FA1 in the form of the FA2 shares it received," s. 87(4)(a) applied to the disposition by Canco of its FA1 shares (assuming that Canco did not elect to have s. 87(8) not apply), rather than draft para. (n) of the definition in s. 248(1) of disposition applying to deem Canco to have not disposed of its shares of FA1. However, draft para. (n) applied so tht FA1 did not realize gain (or loss) on its shares of FA2.
Subsection 87(8.3)
Edward A. Heakes, "Another Wave of Foreign Affiliate Proposals", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1275
Avoidance of s. 85.1(4) eliminated (p. 1276)
It is currently arguably possible to avoid this limitation [in s. 85.1(4) by utilizing a triangular merger structure and relying on the tax-deferred treatment under the foreign merger rules contained in section 87, rather than on subsection 85.1(3). The July 12 Proposals would add a new restriction to the foreign merger rules to deny tax-deferred treatment of the shareholder where the shares of the merged company are excluded property and the shares or substituted property are sold to an arm's length person (or to a partnership that has an arm's length person as a member) as part of the same series of transactions….
Subsection 87(9)
Administrative Policy
5 February 1993 T.I. (Tax Window, No. 29, p.18, ¶2434): The cost amount of Canadian resource properties for purposes of s. 87(9)(c) is nil irrespective whether or not there are undeducted resource pools.
24 June 1991 T.I. (Tax Window, No. 4, p. 7, ¶1315): Discussion of reorganization in which the "bump" is unavailable because after the amalgamation the parent does not own all the shares of the amalgamated corporation.
Schwartz, "Statutory Amalgamations, Arrangements and Continuations: Tax and Corporate Law Considerations", 1991 Conference Report, c. 9.
Richler, "Triangular Amalgamations", March/April 1985 Canadian Tax Journal, p. 374: RC has been willing to accommodate transactions whereby option holders and debenture holders of a predecessor corporation in effect receive options or debentures of the parent on a rollover basis, but it has been unwilling to accede to arguments that the "new shares" referred to in s. 87(9)(c) refer only to the shares of Amalco received by the parent in exchange for its previous shareholding in a predecessor.
Subsection 87(11)
Administrative Policy
2012 Ruling 2010-0355941R3: Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. Target and Subco are continued as one company. The parent of Subco ("Acquireco") receives one Amalco common share for each of its Subco common shares.
The purpose of having Target survive the merger under the plan of arrangement was to allow for an exchange of Target shares for shares of Acquireco to qualify as a reorganization for US income tax purposes for US shareholders of Target, although at the end of the day the Target shareholders received cash consideration from Acquireco instead.
Rulings that the merger will be considered an amalgamation (within the meaning of s. 87(1)) in the context of s. 87(11) ; and that pursuant to s. 87(2)(a), Amalco will be considered to have acquired each capital property of Target within the meaning of s. 87(11)(b).
9 December 2011 T.I. 2011-042807: general discussion of application of s 88(1)(d) to situation in which Parent has two successive vertical amalgamations with its wholly-owned subsidiaries, Subco 1 and Subco 2.
21 March 1997 T.I. 970670: Confirmation that the rules in s. 88(1)(c.3) apply on a vertical amalgamation.
6 February 1997 T.I. 970100 (C.T.O. "Bump where Assets Already Distributed?"): Where in connection with the winding-up of a subsidiary, the subsidiary has already distributed its property to its parent and it is then decided to amalgamate the subsidiary and parent rather than complete the winding-up, the property will not be eligible for the bump under s. 87(11) because it was not transferred "on" the amalgamation.


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Not the highest quality images here, but the girl seems fairly high quality; she's attractive, seems to have a dynamite body and a beautiful all-natural rack. From what we can see I'm not noticing too much to be disappointed about; especially when the clothes come off.
Will submitted these pics of his horny ex girlfriend posing nude in bed. He says that they only dated for two months, but he has never had so much hot sex during that short time; she wanted it all the time. He believes she is a true nympho, and of course there is nothing wrong with that, as long as you're the one on the receiving end. He also says that those natural funbags were the most exquisite tits he's ever experienced, as well. No mention of why they broke-up after such a short time, but usually short term relationships are based on lust and attraction alone. It just takes that long to figure it out. Thanks, Will!
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|Rebecca's Connected World
Service Provider, OTT Vendor, Device Maker: People, Can't We All Just Get Along?
They say that politics makes strange bedfellows. Perhaps the same can be said for the communications arena, where different types of companies often both compete and cooperate. (No, I won't use that overused phrase co-opetition … oops!). Consider please: OTT (over-the-top) providers and device makers who need operator networks and access to the customer; operators who want their customers to have a range of apps, device and content choices, but might feel that they are competing with others when it comes to wallet share and defining the customer experience.
So, what do operators, OTT and device makers really think of each other? Where's the common ground, and where is there disagreement and conflict?
A recent global survey sponsored by Amdocs and conducted by leading analyst firm Coleman Parkes revealed attitudes toward partnering between these three key groups. It offered some very interesting and even surprising findings!
Some might assume that service providers think that they are at war with over-the-top (OTT) players such as Google and Skype. They certainly weren't happy when these players first appeared on the scene and took some major bites out of their revenues. But the reality is that the majority of service providers do not view these companies as a threat.
The survey found that 70 percent of service providers actually see OTT as an opportunity. Taking things a step further, 64 percent of service providers believe OTT vendors bring value to the industry in terms of innovation, and 42 percent say they can offer any service that an OTT player can deliver.
These numbers seem to suggest that OTT players are viewed by service providers as the industry's speedy service innovators, and that service providers see a potential opportunity in partnering with them, and improving on their services.
How will partnering with OTT players provide immediate revenue opportunities for service providers? Sixty-nine percent of OTT vendors believe that developing partnerships is either important, or very important, for ensuring the quality of service (QoS) they need to survive and compete. That sounds like a good entry point for service providers.
Of course, none of the above means that things are totally rosy between service providers and OTT players. Both of these groups, along with device manufacturers, are determined to own the all-important customer relationship (while acknowledging the importance of forming selective partnerships with each other to achieve that goal).
Service providers should approach OTT players from a position of strength, aware that they possess valuable assets that OTT players are lacking. In fact, service providers and OTT players largely agree on what these assets are. Our global survey revealed that OTT players agree with the service providers' assessment that their brand strength, network quality and customer data are important assets. Partnerships that attempt to leverage the value of these assets will be on strong ground.
To tap the opportunities, operators need to take a strategic approach to partnering. That means identifying potential partners and their goals, developing an approach to OTT and device makers (one that takes stock of their viewpoint and benefits), solidifying a leadership position, and recognizing and leveraging their assets.
Because, as our research suggests, many industry players have more in common than they may realize. Or to put it another way: we're all in this together.
Rebecca Prudhomme is vice president of Product & Solutions Marketing at Amdocs . She currently leads Amdocs' entire global team of product marketing professionals focused on bringing to market Amdocs' products, services and solutions.


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Mameshiba on the Loose is the tale of the adventures of a group of beans with tiny dog faces - yes that's right, BEAN DOGS. Bean dogs that love trivia. The book is illustrated by Jorge Monlongo, with scripts by me.
Super Animal Adventure Squad is about the adventures of the world's most elite team of anthropomorphic secret agents, as they thwart evil scientists, battle pirates and eat lots of cake. It is released on the 6th of October 2011 and is completely drawn and written by me. All of it! There is also a facebook page for it here
If you like Beaver and Steve I am pretty sure you will find these books exceedingly enjoyable, so please check them out! (these links will take you to the amazon UK website, but they are also available from many other retailers and will hopefully be in shops too!)
It seems like every time I write here I'm complaining about some sort of ailment. Could this mean that I am not the titan of healthy living I've always though myself to be? Or could it mean I'm just a whining hypochondriac who simpers under the duvet for a week at the slightest sign of a sniffle? No - I am clearly the subject of a protracted viral attack by agent or agents unknown. It is the only explanation. I hope you like the valentine's day card. Steve informs me that from a scientific point of view this card will guarantee what he describes as 'muchos smoochas'. I chose not to pursue the matter further. And if this card isn't high enough resolution for you I've uploaded a high-res version as the vote incentive (though it won't show up in the preview on the right because, well, I'm dumb), so get voting, get printing, and get LOVING.
- James13 Feb 2007
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|Mirë se vini!
|Mirë se vini!
Have a new idea?
|inversion says:
These messages ("Task complete", "1 task postponed") blocks the UI and you need to wait a second to be able to continue interaction with the app. This reduces the performance and efficiency of using experience.
Posted at 3:37pm on July 24, 2011