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Subsection 118.6(2) of the Act reads, in part, as follows: "For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted an amount determined by the formula A x $60 x B (...)" ...

Une CR est assujettie à un impôt (impôt de la Partie XI.3) de 50 % sur ses revenus et sur les cotisations à la CR. ...

With respect to such a property, the Income Tax Act provides that a taxpayer may deduct the amount determined by the following formula from the gain on the disposition (or deemed disposition) of any property that was the taxpayer's principal residence at any time after the acquisition date: 1 + the number of taxation years ending after the acquisition date for which the property was the principal residence and during which Capital gain on he was resident in Canada x disposition the number of taxation years ending after the acquisition date during which the taxpayer owned the property For additional information on the principal residence exemption, you may refer to chapter 8 of the Capital Gains Tax Guide. ...

Income Tax Convention (Convention) which states "... copyright and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work, including royalties from such works on videotape... for private (home) use... ...

The Queen, Dube, J stated "... The Act (Income Tax Act) must be construced according to its own definitions, or the ordinary meaning of the words used, or the common usage by the people in the relevant industry. ...

The Queen, [[1987] 1 C.T.C. 265] [[87 C.T.C. 265 (FCTD), Dube, 3 stated "... ...

Paragraph 18(1)(m) of the Act provides that no deduction shall be made in respect of "... any amount... paid or payable by virtue of an obligation imposed by statute to (i) Her Majesty in right of... a province, (ii) an agent of Her Majesty in right of... a province, or (iii) a corporation, commission or association that is controlled by Her Majesty in right of.. a province or by an agent of Her Majesty in right of.. a province as a royalty, tax..., lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or (v) the production in Canada of... ...

They have the following characteristics: Cost equal to paid-up capital ("PUC") $ 1 Adjusted cost base ("ACB") equal to valuation day amount $1,000,000 Redemption value and fair market value, immediately before Father's death $3,000,000 Those shares were received on the freeze of Father's interest in an operating company. 3. ...

In that year, you have concluded he would report the following income for tax purposes: Interest Income Original Issue Discount 51.48 less Interest Included in A's incom per sub- section 20(14) (20.60) Interest included in B's income 30.88 Capital Gains Total Proceeds Received 100.00 less Proceeds on account of Interest (51.48) Proceeds on Account of Principal Amont 48.52 Cost (price paid less price on account of interest) (56.45- 20.60 = 35.85) (35.85) Capital gain (loss) 12.67 Taxable Capital Gain 6.34 We confirm that the coupon interest of the Bond would be treated according to the usual rules while the original issue discount would be treated in the manner described in the foregoing example. ...

Department of National Revenue response (a) Subject to certain readjustments provided for therein, (b) paragraph 89(1)(c) of the Act provides that the "paid-up capital" in respect of a share of any class of the capital stock of a corporation constitutes "... an amount equal to the paid-up capital in respect of that class of shares at that time, computed without reference to the provisions of this Act... ...