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Clark Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

Vous recevrez, sous pli distinct, le remboursement de votre dépôt au montant de 325,00 $. ...

M.N.R. 49 DTC 602 and Dominion Steel & Coal Corp. Ltd. v. M.N.R. 57 DTC 147- but do not consider either decision of much assistance in resolving the matter, at least beyond their assistance in removing any minor doubt that such hedging gains on hedging arrangements were on income account or were on account of capital. ...

October 11, 1994 T1 Programs Division HEAD OFFICE T1 Assessment & Rulings Directorate Reassessment Section D. ... Paragraph 118.2(2) of the Act states that " For the purposes of subsection (1), a medical expense of an individual is an amount paid... ...

Loans and Grants The provisions of paragraph 12(1)(x) of the Act include in computing a taxpayer's income amounts received from a government or other public authority, in the course of earning income from a business, which "... can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a reimbursement, contribution, allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of the cost of property or in respect of an outlay or expense". ... Loan Write-Off's / Interest Concessions Where a borrower's debt is settled or extinguished without any payment or by the payment of an amount less than the principal amount of such debt, the provisions of subsection 80(1) of the Act may apply to reduce certain income tax deductions otherwise available to such borrower. ...

VOTRE OPINION A la page 2 de votre note de service, vous exprimez l'opinion suivante: «... la fiducie devrait être considéré comme une fiducie administrative et imposé en vertu de 122(1), pour les raisons suivantes. ... Dans cette cause, le juge Monet a précisé à la page 547, ce qui suit: «... s'il est vrai qu'au sens de la Loi de l'impôt sur le revenu "succession" signifie "héritier", il me paraît également vrai que pour continuer à être une succession il faut conserver la qualité d'héritier. ...

F.C.T. ((1946) 72 C.L.R. 634 at 648) Dixon J. of the High Court of Australia stated that the answer to whether an expenditure is on income or capital account, "... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of the legal rights, if any, secured, employed or exhausted in the process. ... Ltd., supra, at p. 648, reminds us that the classification of such expenditures '... depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of legal rights...', supra. ...

Could the following be added to 3(A) "Complete and file form T661 for an R & D claim" to be consistent with the comments on T2038 for use by corporations. ... What is important to note is that investment tax credits earned by a partnership reduce the depreciable property under 127(12) or the R & D pool under section 37 by virtue of subsection 127(12.1) at the partnership level and not at the partner's level. ...

21(1)(b) 12) chapter 7- pages 54 and following We understand that the reference to "qualified expenditures" was dropped deliberately because of the unlikelihood of individuals incurring R & D costs. ... Some of those references have been indicated on attached photocopies of the draft 1989 guide. 13) Pages 56 and 57- ITC's There doesn't seem to be clear information that unused ITCs for properties acquired (or R & D expenditures made) before April 20, 1983 is not available in 1989. ...

Page 2.4, paragraph 2, line 1, we suggest the words "compliance with various notice and other requirements, followed by the filing with the director of "should be added after the words " dissolution under S. 211 requires". ... The Department's position regarding the application of subsection 78(l) and (2) of the Act are as outlined in paragraph 12(h) of IT-l09R which states in part that: "... section 78 will not be applied provided the Department can be assured to its satisfaction that the unpaid amounts will be paid by the parent prior to the respective dates on which subsection 78(1) or (3) would have become operative had the subsidiary not been wound-up". ...