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NOS COMMENTAIRES Tel qu'indiqué aux paragraphes 1 et 2 du Bulletin d'interprétation IT-334R2, l'article 3 de la Loi de l'impôt sur le revenu (ci-après la " Loi ") prévoit que le revenu d'un contribuable, aux fins de l'impôt, inclut, entres autres, ses revenus de toutes sources. ...

With respect to the Campbell case, we outlined our position in our response to Question 2. ...

(in this memorandum we shall refer to these as the "Purchased Assets"), and 2. consideration for the Producer's recognition of the GoC's support for the Production (in the form of end credits) and as financial support in promoting the GoC's initiatives, as outlined above under the "Additional Information" subtitle and as stated in the XXXXXXXXXX of the Agreement (in this memorandum we shall refer to these as the "Advertising Benefits"). ...

It is the TSO's position that the Agreement between XXXXXXXXXX and XXXXXXXXXX represents a quit claim which is subject to the rules of Former Section 79, by virtue of Paragraph 2 of Interpretation Bulletin, IT-505. ...

The requirement in subparagraph (a)(vi) of the definition will be met if the property was owned by, among others, the taxpayer or a spouse, child, or parent of the taxpayer, throughout the 24 months preceding the disposition of the property and, in at least 2 years while the property was so owned, the gross revenue of such an individual from the farming business carried on in Canada in which the property was principally used, and in which such an individual was actively engaged on a regular and continuous basis exceeded the person's income from all other sources for the year. ...

Also, not clear that school provides the specialized equipment, facilities or personnel for the care, or care and training, of individuals with the particular condition suffered by the Patient. 2) XXXXXXXXXX- not clear that school provides the specialized equipment, facilities or personnel for the care, or care and training, of individuals with the particular condition suffered by the Patient. ...

The RRSP annuitant died during the 2000 calendar year, and had no spouse at the time of his death. 2. ...

Ghislaine Landry, CGA pour le Directeur Division des entreprises et des sociétés de personnes Direction des décisions en impôt Direction générale de la politique et de la législation- 2- ...

Some of the salient terms of the agreement, dated XXXXXXXXXX, between the Producer and Telefilm (the "Agreement") under the Low Budget Program are as follows: Section 2- the Production budget was $XXXXXXXXXX; Section 3- Telefilm agreed to advance to the Producer a maximum of $XXXXXXXXXX (the "Advances" being XXXXXXXXXX% of the Production budget) to be used to finance the making of the Production; Section 5- the Producer agreed to pay Telefilm 10% of the "Production Revenues" until the amount of the Advances had been recovered (note: no interest is stipulated on the amount of the Advances); Section 6.05(a) of the Standard Terms- Telefilm was to receive certain on-screen credits for its participation in financing the Production; Section 6.08 of the Standard Terms- the Producer must declare to Telefilm in writing "all other government assistance...received or to be received in respect of the Production... ...

XXXXXXXXXX. 2. Afin de permettre à la filiale d'avoir les liquidités nécessaires pour effectuer le remboursement de ses emprunts, le contribuable lui a avancé en XXXXXXXXXX des sommes totalisant XXXXXXXXXX $ US. ...