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In the situations described above … a direct link should be made between the borrowed money and the funds received on the return of capital or contribution. ...

. … [A]ssuming that all the property transmitted to the various trusts comes from the testator, Mr. ...

If the request for a refund from the Romanian tax authorities is denied and the assessment is upheld, Xco may follow the procedures outlined in Article 25 [re MAP] … and make a written request to the CRA's Legislative Policy Directorate for a foreign tax credit. ...

The fact that the franchisor does not itself deliver the goods does not invalidate the application of subparagraph 20(1)(m)(i) … ...

Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...

11 October 2017 Internal T.I. 2017-0719181I7 F- Agreement in writing-- summary under Paragraph (g.4) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g.4) pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3) Corporation X, which is a principal-business corporation, issues a flow-through share under a written agreement entered into on December 31, 2012, renounces its Canadian exploration expenses under the look-back rule and enters into a written agreement dated June 20, 2013 with a subcontractor for the incurring of pre-production mine development expenses, with the work (entailing payments of Corporation X of $2 million) ending on December 31, 2013. ...

The Taxpayer will issue “Claim Settlement Shares” to Affected Creditors in satisfaction of their Affected Claims (except that “Cash Election Creditors” will receive cash in lieu of such shares – apparently funded out of common share subscriptions by the Plan Sponsor and investors), thereby resulting in a portion of the outstanding principal of the Affected Claims being forgiven The resulting forgiven amount is estimated to be less than the taxpayer’s tax attributes. ...

CRA assumed that the wife will designate Immovable2 as her principal residence for the years 1995 to 2006 inclusive (as well as 1992, 1993, and 1994) and that, as a result, the husband must designate the same property for the years 1995 to 2006 – in which case, Immovable1 would be treated as a capital property subject to the change-in-use rules. ...

. … [I]t is clear from the wording of subparagraph 256(1.2)(f)(ii) that Parliament intended this provision to apply where a person is named as a beneficiary in the trust indenture, and the person's share of the trust's income or accumulated capital is conditional on the exercise or non-exercise of discretion in that regard. ...

. … In the situation described above, the effect of subsection 87(2.1) would be that the Subco2 Loss incurred in its taxation year that ended on December 31, 2003, would become a Amalco2 Loss for the same taxation year. ...