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30 March 1994 Internal T.I. 9336137 - ALLOCATION OF S/H LOAN TO FARM AND P/R

Humenuk 957-8953 Attention: Wayne Hoogsteen 933613 Shareholder Loan used to acquire Farm Property with Residence We are replying to your memorandum of December 2, 1993 concerning an audit of XXXXXXXXXX. ...

4 July 2009 Internal T.I. 9415947 - INTEREST RATE SWAP - TERMINATION PAYMENT/RECEIPT

Attwooll (1967) 2 All E.R. 124 (CA); followed in H.M. v. Manley, 85 DTC 5150 (FCA).) ...

21 November 1994 Internal T.I. 9419616 - RRSP TRUSTS AFTER THE DEATH OF THE ANNUITANT

IT-286R2, in paragraph 2, states that a trust to which paragraph 104(6)(b) applies can deduct such part of its income as was payable in the year to a beneficiary. ...

1 March 1996 Internal T.I. 9605017 - INCOME OF CONTRACTS, GAAP & PART I.3

" It is our understanding that in accounting for long-term construction contracts pursuant to the percentage of completion method the balance sheet generally reflects amounts with respect to (1) accounts receivable including holdbacks and (2) an asset often titled Work-in-process (WIP) or construction-in-process (CIP) the balance of which is composed of actual construction costs plus recognized profit less contract billings. ...

2096 Internal T.I. 9532237 - CONFERRING A BENEFIT ON UTIMATE NONRESIDENT PARENT

Position: Five alternatives were suggested: 1) subsections 15(1), 214(3) and 212(2) 2) subsection 246(1) at Holdco's level 3) subsection 246(1) at Opco's level 4) subsection 56(2) at Holdco's level XXXXXXXXXX Reasons: see document file XXXXXXXXXX GAAR: N/A FINANCE: N/A REVIEW: N/A JURISPRUDENCE: David Smith (93 DTC 5351); Simon-Carves (89 DTC 98); and Indalex (88 DTC 6053) XXXXXXXXXX HEADER DOCUMENT KEY: 7 HEADER DATABASE: 1 HEADER SUBJECT LINE: Conferring a Benefit to Ultimate Nonresident Parent HAA NUMBER: HAA 7761-1 XXXXXXXXXX, 1996 Chief of Audit Foreign Section XXXXXXXXXX Tax Services Office XXXXXXXXXX Attention: XXXXXXXXXX 953223 XXXXXXXXXX Subsections 15(1), 56(2) and 246(1) of the Income Tax Act (the "Act") THIS DOCUMENT CONTAINS ADVICE OR RECOMMENDATIONS DEVELOPED BY A GOVERNMENT DEPARTMENT AND AN ACCOUNT OF CONSULTATIONS OR DELIBERATIONS INVOLVING OFFICIALS OF A GOVERNMENT DEPARTMENT AND IS THEREFORE CONSIDERED TO BE EXEMPT FROM DISCLOSURE UNDER SUBSECTION 21(1) OF THE ACCESS TO INFORMATION ACT. ...

27 May 1993 Internal T.I. 9310007 F - Partnership Holding Real Estate Prop. - 20(1)(c)

Partnership Representative's Comments: 2. XXXXXXXXXX is of the opinion that section 4 of the partnership agreement allowed the partners to contribute their condominium units to the partnership at the outset as a capital contribution. ...

4 February 1994 Internal T.I. 9333597 F - Trucks Hauling Wood Chips - Qualified Property?

This view is also consistent with the comments contained in the first sentence of paragraph 12 of Interpretation Bulletin IT-145R as well as those contained in paragraph 2 of Interpretation Bulletin IT-501 as reflected in the Special Release thereto dated December 30, 1987. ...

20 March 1995 Internal T.I. 9431887 F - CALCUL DU REVENU GAGNÉ

Quant aux autres questions soumises dans votre demande, mentionnons que nous sommes généralement d'accord avec les réponses que vous proposez aux questions 1, 2 (sauf dernière phrase) et 7 à l'égard desquelles nous n'avons aucun commentaire à formuler. ...

31 May 1995 Internal T.I. 9427267 - GOLF MEMBERSHIP

If an activity is not a source of income, subsection 248(1) defining business, subsections 9(1) and (2) dealing with the calculation of income and loss from business or property, as well as paragraph 3(d) cannot apply to allow as a deduction from other income the losses sustained by a taxpayer. ...

29 March 1995 Internal T.I. 9501617 - TRAINING EXPENSES

Accordingly, consistent with the comments in paragraph 2 of IT-357R2 which set out the Department's general position on training expenses, it seems that the cost of these seminars are not in the nature of capital. ...

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