can qualify as self-contained domestic establishment if no ownership but expense responsibility
145
Principales Questions: Que veut dire l’expression « tenait ailleurs et comme lieu principal de résidence, un établissement domestique autonome » au sous-alinéa 6(6)a)(i) ? / What does the phrase « maintained at another location a self-contained domestic establishment » in subparagraph 6(6)(a)(i) mean?
Position Adoptée: Question de fait. Le particulier doit être responsable de l’entretien de son établissement domestique autonome. / Question of fact. The individual must be responsible for the upkeep of its self-contained domestic establishment.
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Submitted by narmstrong on Sun, 03/31/2019 - 21:57
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
If a U.K. resident disposes of shares of its Canadian subsidiary that derive the greater part of their value from rights related to an active oil...
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Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them
categorization of pre-mining expenditures by ITA treatment
580
Principal Issues: What are the types of expenses that would normally qualify as exploration costs under paragraph (f) of the definition of "Canadian exploration expense" in subsection 66.1(6) in the context of a mining project?
Definition of "Canadian exploration expense" in subsection 66.1(6)
Principal Issues: What are the type of expenses that would normally qualify as "Canadian exploration expenses" under paragraph (f) of that defined term in subsection 66.1(6) in the context of a mining project?
Principal Issues: Whether the cost of sperm and/or donor eggs are eligible medical expenses for the purpose of the medical expense tax credit (METC).
Position: Question of fact, but not likely.
Reasons: Costs incurred by an individual for fertility treatments are eligible expenses only if they are paid in respect of a patient who is the individual, their spouse or common-law partner, or, a dependant.
