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Under 13(27)(c) & (28)(d) a t/p is considered to have acquired property immediately before disposition if none of the other times occur earlier. ...

Some important factors to be considered in making such a determination include: • location of the business office- where the books and records are kept- where business transactions with customers and suppliers are arranged- where employees report for work or are paid from- where inventory is ordered and often maintained. ...

Because such income is taxed under Subdivision d of Division B of the Act which is entitled “Other Sources of Income”, rather than under Subdivision b of Division B which is entitled “Income or loss from a business or property”, you suggest that such income would not be “ income from property” for the purposes of various provisions of the Act such as sections 74.1, 110.6 and 207.5. ...

In our view, this position ignores the provisions of paragraph 87(2)(b) and, in particular, the following clause: ”... the property [the inventory] so included shall be deemed to have been acquired by the new corporation at the commencement of its first taxation year for an amount determined in accordance with section 10 thereof for the purpose of computing the income of the predecessor corporation for its last taxation year...” ...

" In addition to the use of the word ancillary, subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...

No reserve would be permitted under subparagraph 20(1)(m)(iii) of the Act, as amounts received for the sale of property would not generally be in respect of "... periods for which rent or other amounts for the possession or use of land or chattels have been paid in advance.... ...

A loan of $300,000 @ 10% provided by the shareholder to the company on January 1, 1980, with no specific terms of repayment and unchanged to date, would have an anniversary date of December 31, 1980 for purposes of subsection 12(4). ...

Si vous étiez membre d'un RPA en 1991, le maximum que vous pouvez déduire pour 1992 au titre de vos cotisations à des REER est égal au moins élevé de $12,500 ou 18 % de votre revenu gagné de 1991, moins votre facteur d'équivalence («FE») de 1991 et votre facteur d'équivalence pour services passés nets («FESP») de 1992. ...

Cet alinéa précise "... d'une hypothèque à l'égard de tout bien immeuble situé au Canada,... ...

In Olympia & York Developments Ltd v The Queen [[1980] C.T.C. 265] 80 DTC 6184, Mr. ...