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Lors d'un projet en 1990, la société a engagé des frais de XXXXXXXXXX $ pour des travaux d'arpentage, des études géotechniques, des plans et devis et des esquisses et maquettes afin d'obtenir un contrat de location à long terme d'un immeuble à être construit (XXXXXXXXXX). ... QUESTION Vous nous demandez si les frais de XXXXXXXXXX $ sont des dépenses de nature courante ou des dépenses en capital admissibles au sens de l'article 14 de la Loi de l'impôt sur le revenu. ...

Thus, any income earned or expense incurred from the swap or other financial derivative would generally not be considered as being derived from the associated asset or liability for which it may be designed to hedge (see document # 2000-0042885). ... If XXXXXXXXXX had been charged only the balance of the termination fee in respect of the issue of the XXXXXXXXXX % Senior Notes, then a case could be made that XXXXXXXXXX should be amortizing a portion of that second termination payment over XXXXXXXXXX years in accordance with paragraph 20(1)(e) of the Act. ...

Simmonds & Sons Limited, 89 DTC 707 (TCC) as follows: Delivery by one party to and receipt by another party of sum of money upon agreement, express or implied, to repay it with or without interest. ... Previously, subsection 237.1(4) of the Act provided that no person shall "... accept a contribution towards the acquisition of, an interest in a tax shelter before... ...

This position is indicated in Issue # 33 of the Mining Industry Audit Issues. ... As indicated in the mid amble before paragraph (d) of that Regulation, "... the taxpayer's incomes and losses are computed in accordance with the Act... ...

Option $ XXXXXXXXXX DR. Contributed Surplus $XXXXXXXXXX CR. Note Receivable $XXXXXXXXXX Given that all of the transactions were completed within the same taxation year, we would not expect to see any amounts reflected in the retained earnings or contributed surplus accounts of any of the three companies with respect to the series of transactions undertaken by them. 4) Based on a review of the Handbook recommendations in respect of capital assets in section 3060, and in particular section 3060.18 which states that "a capital asset should be recorded at cost", it is our view that the assets acquired on the exercise of the Option, while they may be valued at $XXXXXXXXXX, would only be recorded in Company A's books at a carrying amount of $XXXXXXXXXX (i.e. the cost of acquiring the assets was the Option exercise price). ... Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Reasons: 1.must ascertain how the units got into the trust...75(2) may apply to any income & gains earned on these units depending on how the trust acquired the units. 2.As the trust holds the units, the performance fee is not deductible at the trust level. ... April 5, 2001 Arun Khanna Trusts Section Manager V & E L. Holloway (Southern Ontario Region) 957-2104 c/o Toronto West TSO Attention: Navita Uppal 2000-005810 Performance fee of XXXXXXXXXX This is in reply to your e-mail of November 23, 2000, concerning the tax treatment a of "performance fee" charged by the manager of a mutual fund the units of which are held as an investment by an inter vivos trust. ...

Reasons: 1. as per T1 guide and IT-513R- proof of support is required & also taxpayer never resumed cohabitation or cannot provide proof of cohabitation versus visitation. ... This case was validated by the Supreme Court of Canada in M.v H ([1999] 2 S.C.R. 3, 46 R.F.L. (4th) 32) where the following was stated at paragraphs 59 and 60: " Molodowich v Penttinen (1980), 17 R.F.L. (2d) 376 (Ont. ...

Sections 1.5.4 and 5.5.1 of the Program Policy state that assistance under the program is provided based on the needs of the individual and / or family and that there must be a specific unmet need that can be supported by the Program. Section 10 of the Program Policy outlines the individual's / family's ability to cover costs independently and includes an income test. ...

October 17, 2000 Audit Directorate HEADQUARTERS Small & Medium Enterprise David Shugar Division 957-2134 Attention: Diane Favel 2000-004948 Indian Exemption- Employment Income Guidelines This is in response to your correspondence of September 25, 2000, enquiring about Canada Customs and Revenue Agency's (the CCRA) position regarding the evaluation of factors connecting personal property to a reserve. ... In your correspondence you referred to the following answer given to a question from the Department of Fisheries & Oceans: Question 6: If an Indian Fisher incorporates his fishing business and becomes an employee of the corporation, would the employment income received by the Indian Fisher be exempt from taxation? ...

In the present case it remains to be determined whether: the facts (once the type and nature of the TIPs have been established) support a finding (using the guidelines set out in Appeals Decision # 95) that the tenant inducement payments are deductible as running expenses; and XXXXXXXXXX qualifies for this administrative concession regarding taxpayer requested adjustments. ... If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...