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Subsection 103(1) of the Act applies where the principal reason for the agreement to share profits in a certain manner ".... may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under this Act, the share of each member of the partnership in the income or loss, as the case may be,........is the amount that is reasonable having regard to all the circumstances..... ...

Depuis 1987, la municipalité prélève une taxe d'amélioration de quartier de 2 200 $ par année pour les égouts, l'aqueduc, le pavage et l'éclairage. ...

Principal Issues: The basis for determining whether alimony & maintenance income is exempt. ...

May 11, 1995 Appeals & Referrals Division HEADQUARTERS Don Beamish Roberta Albert Section Chief (613) 957-2100 Attention: Alex Lowe 951284 XXXXXXXXXX Interest Income Received by a Status Indian We are replying to your memo of May 4, 1995 concerning a request for an opinion relating to the above-noted status Indian which you received from Toronto Designated Appeals. ...

Raisons POUR POSITION ADOPTÉE: La position du Ministère dans le dossier # 7-932735. ...

Reasons FOR POSITION TAKEN: The Coopers & Lybrand case changed the way the courts applied the M&P tax credit by determining the real source of income i.e. the sale of goods or the service provided. ...

January 9, 1996 Ottawa Taxation Centre HEADQUARTERS Enquiries & Adjustments M. ...

For example, if in a calendar year a donor makes 3 donations of $100 each to a particular registered charity and in respect of the second donation receives an article valued at $90, the eligible amount of the donor's gifts will be determined as follows: Gift #1 Gift #2 Gift #3 Property (cash) given to the charity $100 $100 $100 Advantage received 0 90 0 Eligible amount $100 $ 0* $100 *The eligible amount is zero because the amount of the advantage exceeds 80% of the FMV of the property transferred to the charity. ...

Serge Vallieres Income Tax Rulings Directorate Ottawa Tax Services Office Randy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2003-002851 Re: Mutual Fund Sales Reported By A Professional Corporation We are writing in response to your memorandum of July 4, 2003, wherein you inquire further to our letter of April 14, 2003 (our file 2003-000908), issued in response to your inquiry of March 18, 2003, concerning the above-noted issue. ...

Yours truly, Mark Symes Corporate Reorganizations Section 1 Income Tax Rulings Directorate Policy & Legislation Branch ...