Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to...

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Principle Issues: Is the reimbursement by an employer of certain moving expenses incurred by an employee a taxable benefit under paragraph 6(1)(a)...

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Principal Issues: 1) Can the CRA confirm that the Additional Subsidized Childcare Contribution in Quebec is deductible in computing an...

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Principal Issues: 1) Should there be tax withholding on payments, that are not taxable per paragraph 81(1)(a), made to a participant of a PRPP who...

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Principal Issues: Would an entity, who is a non-profit organization per paragraph 149(1)(l), lose its tax-exempt status due to a clause in its...

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Principal Issues: 1. Does the definition of member pursuant to subsection 135(4) apply to define a member of a cooperative corporation for the...

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Principal Issues: Whether a joint election, as defined in subsection 60.03(1), can be made by a pensioner and a pension transferee where (1) the...

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Principal Issues: Whether subsection 256(1.3) applies when a child is 18 years old at the end of the taxation year of a corporation to determine...

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3 December 2015 T.I. 2015-0613761E5 F - Capital Dividend Account-translation

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