Search - كليشات مرتبطين

These are additions to our set of 3,129 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2000-11-24 3 November 2000 External T.I. 2000-0047535 F- CHNT USAGE-UN IMMEUBLE Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) building of the taxpayer with 4 units treated as 4 separate properties for purposes of the change-in-use rules Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(b)- Subparagraph 13(7)(b)(ii)- Clause 13(7)(b)(ii)(B) change in use of unit in 4-plex from personal to rental and vice versa 31 October 2000 Internal T.I. 2000-0048427 F- PENSION ALIMENTAIRE-ARRERAGES Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount amount of support can be payable under a court order although the amount paid is less 10 November 2000 External T.I. 1999-0008335 F- inclusion revenu exonéré- convention fiscale Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(a) requirement to include a treaty-exempt receipt in income 9 November 2000 External T.I. 2000-0038955 F- CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) ascertaining 5-year earnout period / meaning of “calculated with certainty” 7 November 2000 External T.I. 2000-0040615 F- OPTIONS ET CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) IT-426 cost-recovery method not available where earnout is embedded in the variable proceeds received for the granting of a share-sale option with nominal exercise price Income Tax Act- Section 49- Subsection 49(1) granting of earnout option may require full recognition under s. 49(1) on grant date/ legal form of option v. share sale generally followed 7 November 2000 External T.I. 2000-0041815 F- ALLOC. ...

These are additions to our set of 3,174 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,188 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,195 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,209 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,221 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-02 29 April 2025 External T.I. 2024-1036641E5 F- Relevant Group Entity Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(c)- Subparagraph 84.1(2.31)(c)(iii) a Realtyco, whose shares qualified as QSBCS based on a related corporation’s active business, would be a “relevant group entity” on a sale of the latter’s shares Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(iii) continued control of the related lessor to an Opco would violate the s. 84.1(2.32)(c)(iii) condition on a sale of Opco to a child’s purchaser corporation 2000-06-23 10 May 2000 Internal T.I. 2000-0016257 F- RPA COTISATIONS POUR SERVICES ANTERIEURS Income Tax Act- Section 147.2- Subsection 147.2(4)- Paragraph 147.2(4)(c) no retroactive deduction 19 May 2000 Internal T.I. 2000-0018477 F- DEDUCTION A LA SOURCE Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(j) amounts paid out of RRSP to trustee in bankruptcy pursuant to judgment were subject to source deductions even though no mention thereof in court order 2000-06-09 8 June 2000 External T.I. 1999-0006105 F- TRANSFERT DE BIENS A UN CONJOINT Income Tax Act- Section 74.1- Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt 15 May 2000 Income Tax Severed Letter 2000-0008210 F- ADMINISTRATEUR DE FACTO Income Tax Act- Section 227.1- Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name 31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual” 5 June 2000 External T.I. 2000-0010615 F- Developpement d'un equipement- RS&DE Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses ...

These are additions to our set of 3,310 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,330 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...