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On November 2, 2023 (after their having entered into the purchase agreement) he withdrew funds from his FHSA. ...

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 11, 2024-1031061C6 F- Remboursement dans le cadre du RAP- Repayment und-- summary under HBP Balance Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- HBP Balance where opening HBP balance is repaid in Year 1 with RRSP contribution, the HBP balance is not reduced until the Sched. 7 is filed in March of Year 2 An individual, who had an HBP balance of $5,000 at the beginning of the year 202X, contributed $5,000 to his RRSP on May 7, 202X to repay that HBP balance. ...

., success or failure of one activity will tend to result in success or failure of the other). 2) In circumstances where a U.S. resident realizes a gain from the disposition of the shares of a Canadian subsidiary, and the value of the shares of the subsidiary is attributable partly to a connected business and partly to a business that is not connected to the relevant U.S. trade or business, we would consider only the portion of the gain that relates to the connected business to be income described in paragraph XXIX A(3). ...

Under ITR paragraph 103(6)(a), a payment described in subparagraph 40(1)(a)(i) or (iii) or paragraph 40(1)(c) of the Income Tax Application Rules (footnote 2) constitutes a "lump sum payment" for the purposes of ITR subsection 103(4). ...

For example, Section 3 of Part 2 of the supplement, and Sections 1-4 of Part 3 of the supplement, specifically refer to taxation years of the affiliate ending before the entity’s taxation year, whereas here the amalgamation would not cause a year-end for the foreign affiliates. ...

Paragraph 2 of Article 22 (Source of Income) of the Treaty provides that for the purposes of Article 23 (Elimination of Double Taxation) and the law of Canada, profits, income or gains of a resident of Canada which are taxed in Australia in accordance with Article 13 of the Treaty shall be deemed to be income from sources in Australia. ...

In that situation, there could be a favourable ruling because Parentco thus had transferred enough ACB in the shares of Subco 1 to Newco to cover the ACB of the assets that were then transferred by Subco 2 to Newco. ...

“The loan is not made on account of or in full or partial payment of a withdrawal of a limited partner's capital contribution.” 2. ...

Consequently, the GRE could be considered to have made a gift of the capital interest in the CRT to the qualified donee at the time the CRT is created by GRE and the capital interest vests in the qualified donee, provided that all of the conditions set out in paragraph 2 of IT-226R are satisfied. ...

Society of Composers, Authors and Music Publishers of Canada [2012] 2 S.C.R. 231 drew a clear distinction between the right to perform in public and the right to produce or reproduce a copyrighted work. ...