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May 20, 2010 Patrick Massicotte Income Tax Rulings Senior Analyst Directorate Competent Authority Services Yannick Roulier International & Large Business, Compliance Programs (613) 957-2134 Canada Revenue Agency Enterprise Building 427 Laurier Ave. ...

September 9, 2010 WINNIPEG TAX CENTRE HEADQUARTERS Individual & Benefit Services Division Income Tax Rulings Directorate Attention: Cyndi Martin-Conway Rita Ferguson 519-645-5261 2010-037408 Deduction of Legal Fees We are writing in response to your request for a Technical Interpretation on the matter of expenses deductible under paragraph 60(o) of the Income Tax Act (the "Act"). ...

Such grants are included in income under paragraph 12(1)(x) when none of the exceptions described in ¶ 8 applies. ...

To quote from CRA Views # 2009-0347291C6 (which provides both the English and French versions of question #3 from the Foundation's Roundtable), "whether a corporation has conferred a benefit on a shareholder for subsection 15(1) ITA purposes is generally one of fact. ...

Specifically, you refer to the comments in paragraph 6 of Interpretation Bulletin IT-268R4, Inter Vivos Transfer of Farm Property to Child which states in part: "... subsection 73(3) applies only to property owned by the parent immediately before the transfer to a child and thus is not applicable to property owned at that time by a partnership or corporation. ...

Poulin wanted to leave Amiante, selling his interest in it at the best price and under the most optimal possible conditions — one of which was to benefit from his capital gains deduction. ...

With respect to the time between the First Segment and the Second Segment, the Commentary states that “ [a] site continues to exist until the work is completed or permanently abandoned. ...

The XXXXXXXXXX stresses on "XXXXXXXXXX " It is reasonable to assume that there is a sense of communality with in the organization. ...

The Asset Consolidation is subject to the prior approval by special resolution (XXXXXXXXXX % vote) of the Class A Shares, XXXXXXXXXX. ...

The dividends payable will be calculated by reference to the redemption price of the New Cansub Preferreds and a floating rate XXXXXXXXXX % in excess of the interest rate payable on the New Opco Demand Loans (defined in paragraph 82 above): c) redeemable at the option of issuer for an amount equal to the issue price in XXXXXXXXXX plus any accrued but unpaid dividends, by New Cansub; d) retractable at any time at the option of the holder for an amount equal to the issue price in XXXXXXXXXX plus any accrued but unpaid dividends; and, e) entitled to priority over the common shares of New Cansub and all other shares ranking junior to the New Cansub Preferreds with respect to the payment of dividends and the distribution of assets of New Cansub in the event of any liquidation, dissolution or winding-up of New Cansub or other distribution of assets of New Cansub among its shareholders for purposes of winding-up its affairs. 86. ...