|
2001-01-19 |
5 January 2001 External T.I. 2000-0010905 F - Valuation - Freeze shares |
Income Tax Act - Section 86 - Subsection 86(1) |
right to retract freeze preferred shares must not be fettered |
|
2001-01-19 |
5 January 2001 External T.I. 2000-0010905 F - Valuation - Freeze shares |
General Concepts - Fair Market Value - Shares |
requirement to seek consent detracts to retraction detracts from FMV of freeze preferred shares |
|
2001-01-19 |
4 January 2001 External T.I. 2000-0047605 F - FRAIS DE DIVERTISSEMENT |
Income Tax Act - Section 67.1 - Subsection 67.1(1) |
attending shows in order to identity artist recruits might be entertainment |
|
2001-01-19 |
4 January 2001 External T.I. 2000-0047605 F - FRAIS DE DIVERTISSEMENT |
Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) |
s. 67.1(2)(a) exception unavailable for tickets to shows attended to recruit artists |
|
2001-01-19 |
10 January 2001 External T.I. 2000-0049585 F - DEDUCTIBILITE DES INTERETS |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) |
annual payment cap on interest until maturity did not preclude deductibility |
|
2001-01-19 |
5 January 2001 Internal T.I. 2000-0053767 F - IT-92R2 Paragraphe 1 |
Income Tax Act - Section 9 - Timing |
progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner |
|
2001-01-19 |
5 January 2001 Internal T.I. 2000-0053767 F - IT-92R2 Paragraphe 1 |
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) |
construction holdbacks not receivable until approved for release |
|
2001-01-05 |
19 December 2000 External T.I. 2000-0035685 F - RPA TRANSFER AU DECES |
Income Tax Act - Section 147.3 - Subsection 147.3(7) |
deceased member can have had more than one qualifying spouse or partner |
