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These are additions to our set of 2,143 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,151 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,216 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 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,257 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 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,271 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 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,290 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 18 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 246- Subsection 246(1)- Paragraph 246(1)(a) s. 246(1)(a) application re mother’s use of a car of Opco controlled by her son’s Holdco to her rather than son turned on whether her minority Holdco had significant influence over Opco Income Tax Act- Section 15- Subsection 15(5) application of s. 15(5) to shareholder’s use of company automobile Income Tax Act- Section 10- Subsection 10(1) automobiles in car dealer inventory used for employee’s personal use remained in inventory, cf. if converted primarily to personal use of shareholder (which would not be a disposition) Income Tax Act- Section 9- Computation of Profit conversion of automobile in car inventory to personal use of CEO would not entail its deemed disposition nor would the conversion of car inventory to personal use of shareholders 2003-11-07 30 October 2003 External T.I. 2003-0037465 F- Subsections 40(3.3) & 40(3.4) Also released under document number 2003-00374650. ...

These are additions to our set of 2,363 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 19 ¼ years of releases of such items by the Directorate. ...

Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) payment of deferred commission amounts held as contingency loss reserve from old employer to new employer was a payment of “remuneration” subject to withholding General Concepts- Payment & Receipt constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer 2003-10-03 24 September 2003 External T.I. 2003-0028145 F- DON FAIT PAR UN PARTICULIER NON-RESIDENT Also released under document number 2003-00281450. ...

These are additions to our set of 2,417 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 19 ½ years of releases of such items by the Directorate. ...