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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2 October 2015 T.I. 2012-0463801E5 F - Capital gains deduction - fishing license

Principal Issues: Whether the wording of clause...

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28 July 2015 T.I. 2015-0585431E5 F – Legal Fees-translation

Principal Issues: Are legal fees incurred against a hidden defect lawsuit following...

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10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Signing Bonus for supply agreement

Principal Issues: 1) Is the amount received by a...

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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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