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DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” – but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time. ...

did=117&lang=eng#tc-tm_4_1 … includes a link to the kilometric rates for each Canadian province and territory. ...

Therefore, on the basis of the documents submitted, it is our view that the promissory note constitutes absolute payment and … pursuant to subsections 28(1) and 76(1) of the Act, the amount of the promissory note received in respect of the cattle and feed inventory should have been included in the taxpayer's income for the year of the disposition. ...

12 March 1998 External T.I. 9805215- Barbados trust deemed resident of Canada-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Before concluding that Canada had the right to tax a trust that was resident in Barbados and which was deemed to be resident in Canada under s. 94(1)(c), Revenue Canada stated: "... ...

Therefore, the applicable penalty provided by paragraph 162(7.01)(b) … is $15, multiplied by the number of days, not exceeding 100, during which the failure continued. ...

"... the Department has decided that 'portfolio investments' as used in subsection 206(1) of the Act takes on its common dictionary meaning of 'all the securities held by an investor'. ...

FEES-- summary under Paragraph 146(2)(c.4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(c.4) reimbursement of fees charged from transfer from registered plan to RRSP not an advantage Regarding whether there is an advantage under s. 146(2)(c.4) where there is a payment by a financial institution into a taxpayer's RRSP as a reimbursement of administration fees charged to a registered plan in respect of the transfer of assets from the registered plan to the RRSP issued by the financial institution, the Department stated: [T]he payment by a financial institution into a taxpayer's RRSP as a reimbursement of administration fees charged to a RRSP, deferred-profit sharing plan, registered pension plan or registered retirement income fund of the taxpayer in respect of the transfer of assets from the registered plan to the RRSP issued by the financial institution, is not an advantage for the purposes of paragraph 146(2)(c.4) …. ...

" However, on the acquisition of the common shares by virtue of the conversion of the preferred shares to common shares, the foundation would be providing the preferred shares as consideration. ...

28 February 1995 External T.I. 9421715- COMMUNICATIONS AND BRANCH TAX-- summary under Subsection 219(2) Summary Under Tax Topics- Income Tax Act- Section 219- Subsection 219(2) "... ...

"... Where an employee undertakes a course of studies as a means of enhancing his chances of a promotion in the short term or enhancing his overall career opportunities in the long term, then the primary benefit is considered to be derived by the employee even though the employer may also benefit from the employee's higher level of education". ...