Principal Issues: Will subsection 74.4(2) apply to both scenarios presented?

Position: No in the first scenario. May technically apply in the...

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Principal Issues: Are funds accumulated in AgrInvest and Agri-Québec accounts eligible properties for the definition "share of the capital stock...

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Principal Issues: Will subsection 74.4(2) apply in the scenarios described?

Position: No in the first scenario. Probably in the second scenario....

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Principal Issues: 1. Whether a severance payment to an employee who performed services on exploration projects would be part of the Canadian...

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Principal Issues: Several questions regarding the medical expense tax credit.

Position: See document.

Reasons: See document.

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Principal Issues: What is the tax treatment of some sponsorship expenses made to a golf club?

Position: None. General comments.

Reasons: Question...

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Principal Issues: 1. Whether subparagraph 53(2)(c)(v) would apply to the loans in the situation described in the letter 2. Whether the limited...

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Principal Issues:

1) Do the taxpayer's activities qualify as a source of income?

2) If the taxpayer is carrying on a business, are the allowable...

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Principal Issues: Prior to the sale of the shares of a corporation to an arm’s length purchaser, in a situation where paragraph 7(1)(b) applies,...

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