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1999-12-10 |
16 September 1999 Income Tax Severed Letter 9913210 F - SYNDICAT DE COPROPRIÉTAIRES |
Income Tax Act - Section 248 - Subsection 248(1) - Corporation |
syndicate of co-owners is a corporation |
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1999-12-10 |
16 September 1999 Income Tax Severed Letter 9913210 F - SYNDICAT DE COPROPRIÉTAIRES |
Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) |
potential for distribution of income on its liquidation would not cause a syndicate of co-owners to not qualify as an NPO |
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1999-12-10 |
24 June 1999 Internal T.I. 9913420 F - BFT- HONORAIRE DE GESTION |
Income Tax Regulations - Regulation 5202 - Cost of Labour |
cost of labour included only the salary component of managementco fees |
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1999-12-10 |
24 June 1999 Internal T.I. 9913480 F - BIA REGROUPEMENT D'ENTREPRISE |
Income Tax Regulations - Schedules - Schedule II - Class 14.1 |
fees incurred in acquiring a similar business may be eligible capital expenditures |
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1999-12-10 |
27 July 1999 Internal T.I. 9913490 F - LOCATION- MONTANT REÇU- JUGEMENT |
Income Tax Act - Section 9 - Compensation Payments |
amount received for a release could constitute proceeds of disposition of a right |
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1999-12-10 |
27 September 1999 Internal T.I. 9916367 F - REMISE DE DETTE/PRET ETUDIANT |
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) |
partial loan repayments where students achieved their degrees were prizes for achievement |
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1999-12-10 |
27 September 1999 Internal T.I. 9916367 F - REMISE DE DETTE/PRET ETUDIANT |
Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount |
partial repayment of loans under a Quebec government program did not represent loan forgiveness (the lenders themselves did not forgive the loans) |
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1999-12-10 |
29 June 1999 APFF Roundtable Q. 12, 9913090 F - DÉDUCTIBILITÉ DES INTÉRÊTS |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) |
interest non-deductible where there is no expectation of profit from the investment |
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1999-12-10 |
8 June 1999 APFF Roundtable Q. 51, 9913160 F - PAIEMENT INCITATIF À LA LOCATION |
Income Tax Act - Section 9 - Timing |
Canderel indicates that the onus is on CCRA to demonstrate that its income computation method provides a more accurate picture/ those in identical fact situations to Canderel can currently deduct their unamortized TIP balance |
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1999-11-26 |
20 October 1999 External T.I. 9904125 F - TRANSFORMATION D'ARTICLES DESTINÉS À LA VENTE |
Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits |
subcontractor’s manufacturing of parts out of materials owned by the car manufacturer could qualify |
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1999-11-26 |
25 October 1999 External T.I. 9908775 F - RESIDENCE-ACTIF ADMISSIBLE |
Income Tax Act - Section 110.6 - Subsection 110.6(1) - Interest in a Family Farm or Fishing Partnership - Paragraph (a) - Subparagraph (a)(i) |
farming partnership residence for on-call partners is used in the farming business |
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1999-11-26 |
25 October 1999 External T.I. 9910355 F - TRANSFORMATION D'ARTICLES DESTINÉS À LA VENTE |
Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits |
subcontractor to goods vendor doing processing of such goods can qualify |
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1999-11-26 |
25 May 1999 Income Tax Severed Letter 9913410 F - VALEUR DÙN CAAF |
Income Tax Act - Section 68 |
where saw mill sold and timber supply agreement relinquished, s. 68(1) could apply to allocate a portion of such proceeds to such agreement |
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1999-11-26 |
29 August 1999 Income Tax Severed Letter 9923446 F - ACTIONS ACCRÉDITIVES-MODIFICATION DU PBR |
Income Tax Act - Section 66.3 - Subsection 66.3(3) |
flow-through shares have deemed nil cost even if CEE deduction subsequently denied |
