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. … In finding that this exception to a taxable benefit was inapplicable, CRA stated: According to the CRA, a pick-up point is a common place specifically designated by the employer for that purpose to which all employees must go. ...

Since … the loan from M Co is assistance that is required to be included in Prod Co's income under paragraph 12(1)(x), the conversion of the loan by M Co into shares of Prod Co at the end of the production would not engage the application of subsection 80(2). ...

Did the interest-free loan generate Part XIII tax and, if so, who had the obligation to collect and remit the tax – and how could it be collected? ...

. … Since Schedule I does not address this situation, the Payment is subject to subsection 106(1). ...

. … Whether the Minister agrees to the request would depend on the particular facts of the situation. ...

. … The income of the Trust for the XXXXXXXXXX taxation year would be computed under Canadian rules pursuant to section 250.1 and would include the $XXXXXXXXXX dividends received. ...

. … [I]f the trust continues to exist after deregistration and the shares of the cooperative are not transferred to the annuitant in the year of deregistration or are transferred in a year subsequent to the year in which subsection 146(12) applies, we are of the view that no withholding tax is required under the application of the provisions of the Act and Regulations since no payment is made on deregistration and in the year of deregistration. ...

. … [U]nlike paragraph 251(5)(b), the definition of term preferred share does not contain the exception that applies where one or more of the rights referred to in that provision cannot be exercised at that time because the exercise of the rights in question depends on the death, bankruptcy or permanent disability of an individual. ...

. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

3 November 2004 Internal T.I. 2004-0083791I7 F- Paragraphe 44.1(2)-- summary under Subsection 44.1(8) Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(8) pre-condition of carrying on business not satisfied / general overview provided A newly-formed corporation used its cash share subscription proceeds almost entirely to purchase a piece of land for which, to date, a required zoning change has not yet been obtained. ...