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It should be taxed in the same proportion as the subsequent / resulting employment income. ...

" As you note, paragraph 87 of IT-151R5 states, in part "... corporations (and associated corporations) whose taxable capital employed in Canada in the previous taxation year... exceeds $15 million will not have a business limit (see paragraph 81) and, therefore, will not meet the conditions to be a qualifying corporation. ...

Lloyd Clark & Co. Ltd. (1970 CarswellNat 142), the Tax Appeal Board stated: "...that payment of a purchase price is basically not effected by the delivery of a promissory note unless the governing agreement for sale provides specifically for that particular mode of payment... ...

August 26, 2004 INTERNATIONAL TAX DIRECTORATE HEAD OFFICE Non-resident Operations Division Income Tax Rulings Returns Processing & Compliance Directorate R. ...

DOCUMENT TYPE: Tax Services Office Memo – 2001-007735 Principal Issues: Are amounts received from a deceased sister’s U.S. pension plans taxable in the hands of the Canadian beneficiary Position: Yes. ...

How long does the dependent have to reside with parent / guardian in order to qualify for equivalent-to-spouse credit? ...

À moins d'indication contraire, tous les renvois législatifs ci-après sont des renvois aux dispositions de la Loi de l'impôt sur le revenu, " la Loi". ...

For the purposes of the Act, subsection 251(2) provides that, persons related to each other are: individuals connected by blood relationship, adoption, marriage or common-law partnership; a corporation and a person that controls the corporation a person who is a member of a related group that controls the corporation, or any person related to a person described in either of the above two situations; and * any two corporations if they are controlled by the same person or group of persons, if each of the corporations is controlled by one person and the person who controls one of the corporations is related to the person who controls the other corporation, if one of the corporations is controlled by one person and that person is related to any member of a related group that controls the other corporation, if one of the corporations is controlled by one person and that person is related to each member of an unrelated group that controls the other corporation, (v) if any member of a related group that controls one of the corporations is related to each member of an unrelated group that controls the other corporation, or (vi) if each member of an unrelated group that controls one of the corporations is related to at least one member of an unrelated group that controls the other corporation. ...

Storry GAAR & Technical Support Section 957-3499 2000-005101 Strong Currency Loan Hedged by a Cross Currency Interest Rate Swap This is in reply to your memorandum of October 11, 2000, wherein you requested our views regarding payments made under a cross currency interest rate swap and whether such payments should be recharacterized as interest for purposes of Part XIII of the Income Tax Act (the "Act") when the desired currency was Canadian dollars and when the parties to the swaps and the underlying loans being hedged are all related. ...

July 13, 2001 Toronto Centre Tax Services Office HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...