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. … The limited partners did not really seem to have a choice as to whether or not they would agree to guarantee the LP loan. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...

In this regard, the Directorate noted that, by virtue of s. 118(5), in order to claim the wholly dependent person credit in respect of the second child, no amount of child support could have been paid in respect of that child – and noted that “[i]n order for subsection 118(5) to apply, the support payments do not have to be deductible.” ...

“[I]t is not necessary for the purposes of subparagraph 122.3(1)(b)(i) that this contract be with the person who undertakes the qualifying activities or that the qualifying activities be undertaken directly by the specified employer under this contract, as long as the services provided by the specified employer under the contract to which it is a party are related to a contract entered into by another party with respect to those qualifying activities ….” ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition damages received for use of a property contrary to the recipient’s co-ownership right were tax-free receipts After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieur obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

Before concluding that such terminal loss should be denied because the building did not qualify as depreciable property (it was not acquired for rental-income purposes notwithstanding its temporary generation of rents), the Directorate stated: [M]ost of the moving costs … should be added to the cost of the cleared land since the purpose of the move was to clear the land rather than to advantageously locate the building. ...

In finding that such compensation was taxable to them (and likely employment income rather than business income), the Directorate stated: [T]he reward received by the crew members was not a windfall …. ...

. … [T]he estate's first taxation year is the subsequent taxation year referred to in subparagraph 161(7)(a)(iv.2) and subparagraph 161(7)(b)(ii). ...