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You summarize XXXXXXXXXX position as follows: "... farm property includes all property used in or suitable for farming and would include particularly property used or usable by persons for farming activities, or rented out by persons for farming activities, whether or not a business of farming is carried on on the property (for profit or otherwise). ... In this case, the particular context is to be derived by considering the entire portion of the relevant text, which is as follows: "... was in respect of the insurance of farm property, property used in fishing, or residences of farmers or fisherman". ... The following are noted. 1.Subsection 248(1) defines "home relocation loan", paragraph (b) of which reads, in part, as "the loan is used to acquire a dwelling, or... the right to inhabit a dwelling..., where the dwelling is for the habitation of the individual and is the individual's new residence" (emphasis added). 2.Subsection 248(1) defines "self-contained domestic establishment" as "a dwelling-house, apartment or other similar place of residence in which place a person as a general rule sleeps and eats" (emphasis added). 3.Section 231 defines "dwelling-house" as "the whole or any part of a building or structure that is kept or occupied as a permanent or temporary residence and includes (a)... and (b) a unit that is designed to be mobile and to be used as a permanent or temporary residence and that is being used as such a residence" (emphasis added). 4.Section 54 defines "principal residence" as "... property that is a housing unit, a leasehold interest in a housing unit or... the right to inhabit a housing unit... and... ...

The defined terms of the Agreement are found under Article 1 which states in part: Article 1 Definitions For the purpose of the present Agreement: [...] (a) "Organization" means the International Civil Aviation Organization, established under Article 43 of the Convention on International Civil Aviation, signed at Chicago on December 7, 1944; [...] (c) "Official of the Organization" means the President of the Council, the Secretary General and internationally recruited staff of the Organization in professional and higher categories and other staff employed by the Organization on the basis of a letter of appointment or a contract; (d) "Member States" means the States that are parties to the Convention on International Civil Aviation; (e) "Mission" means a mission of permanent character representing a Member State to the Organization, established in Canada by that State; (f) "Head of the permanent mission" means the person charged by a Member State with the duty of acting in that capacity; (g) "Premises of the mission" means the offices occupied by a mission, including the residence of the head of mission; (h) "Permanent Representative" of a Member State means the head of mission and other officers of a mission, but excluding administrative and service staff; (i) "Representative" of a Member State means a representative other than a Permanent Representative and shall include all delegates, deputy delegates, advisers and experts; [...] ...

April 3, 2002 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division Karen Power, CA T1 Taxpayer Requests (613) 957-8953 XXXXXXXXXX 2002-012642 Business Income Earned by a Status Indian This is in reply to your letter of March 1, 2002, wherein you request our views on the tax treatment of business income earned by a status Indian. ... M.N.R., 48 D.L.R. (3d) 613 at 616, Chief Justice Jackett stated that: '... as far as I know, under no system of law in Canada, does knowledge, skill or experience constitute "property" that can be the subject matter of a gift, grant or assignment... ... The provision therefore cannot apply.' To this, I would add that wages are not purchased but paid and that the result of such a proposition would affect all the departmental employees in a strange manner especially if one reads subsection 90(2) of the Indian Act, which states: 'Every transaction purporting to pass title to any property that is by this section deemed to be situated on a reserve, or any interest in such property, is void unless the transaction is entered into with the consent of the Minister or is entered into between members of a band or between the band and a member thereof.' " This case is not conclusive with respect to paragraph 90(1)(a) of the Indian Act and business income. ...

Our comments Qualifying rent expense is defined in subsection 125.7(1) of the Act and means, in respect of a qualifying property for an eligible entity for a qualifying period, the amount determined by the formula A – B. Variable A is the lesser of $75,000 and the total of all amounts paid (or payable in certain circumstances) – under a written agreement entered into before October 9, 2020, or pursuant to the renewal (on substantially similar terms) or assignment of a written agreement entered into before October 9, 2020 – in respect of the qualifying period by the eligible entity to a party with which the eligible entity deals at arm’s length. ...

Prior to the enactment of section 247 on XXXXXXXXXX, a transfer pricing rule was contained in subsection 69(2), which read as follows: “(2) Unreasonable consideration — Where a taxpayer has paid or agreed to pay to a non-resident person with whom the taxpayer was not dealing at arm’s length as price, rental, royalty or other payment for or for the use or reproduction of any property, or as consideration for the carriage of goods or passengers or for other services, an amount greater than the amount (in this subsection referred to as “the reasonable amount”) that would have been reasonable in the circumstances if the non-resident person and the taxpayer had been dealing at arm's length, the reasonable amount shall, for the purpose of computing the taxpayer's income under this Part, be deemed to have been the amount that was paid or is payable therefor.” ... (footnote 7) Subsection 247(2) applies in situations where a taxpayer or a partnership and a non-resident person with whom the taxpayer, the partnership or a member of the partnership does not deal at arm’s length (or a partnership of which the non-resident person is a member) are participants in a transaction or a series of transactions and: (a) the terms or conditions of the transaction or series [...] differ from those that would have been made between persons dealing at arm’s length, or (b) the transaction or series i. would not have been entered into between persons dealing at arm’s length, and ii. can reasonably be considered not to have been entered into primarily for bona fide purposes other than to obtain a tax benefit. ... It is not known whether this entity is the same as the current Parent, but we have assumed that it is. 2 idem 3 This figure is described in your request as an amount showing on Holdco’s books. 4 Canadian Economic Observer: Historical Statistical Supplement: Table 7.1 — Interest rates and exchange rates (statcan.gc.ca) 5 Information obtained from a memorandum prepared by Appeals HQ dated XXXXXXXXXX, addressed to the Chief of Appeals at the XXXXXXXXXX. 6 See Department of Finance Consolidated Explanatory Notes 7 See Annex 6 to the 1997 Budget Plan. ...

Fawcett & Son, Limited v. The Queen, [1980] C.T.C. 293 80 D.T.C 6195. ... Fawcett & Son, Limited v. The Queen, [1980] C.T.C. 293 80 D.T.C 6195, no difference should be drawn between Mr. ... Yours sincerely, XXXXXXXXXX for Director Partnerships and Corporate Financing Section Reorganizations Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 BC Income Tax Act [RSBC 1996] CHAPTER 215 << Full Multi- Income Tax Act (gov.bc.ca)>>. 2 Note XXXXXXXXXX are used interchangeably in legal documentation and supporting working papers. 3 BC tax credits are part of the tax administration agreement conclude with the province. 4 As noted above, the relevant part of the definition of “Canadian labour expenditure” in subsection 125.5(1) is the same as “labour expenditure” in subsection 125.4(1). ...

Les contrats de travail sont, pour la majorité, de 27 jours travail / 5 jours congé ou de 54 jours travail / 10 jours congé. ... Les employés qui ont un contrat de travail 27 jours travail / 5 jours congé cumulent leurs journées et préfèrent retourner à leur résidence à tous les 54 jours. ...

7 June 2012 Internal T.I. 2012-0435561I7- Refunds on Post-Bankruptcy Returns Unedited CRA Tags S. 164(1) & (1.5); 128(2), 150(1), 249(1) ITA. ...

Yours truly Stéphane Charette CPA, CMA, MBA Acting Manager Business & Employment Income Section I Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 TCC 2011-1748(IT)G. ...

Deloitte & Touche Inc., [2007] 2 C.T.C. 253, 30 C.B.R. (5th) 81, (Sask. ...