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If the facts show that it is only the time of payment that is not precisely established, but that there is no uncertainty as to the payment of the amount … it could then be a future obligation to pay and not a contingent obligation. ...

. … [N]o partner should be allocated an amount of income greater than the income realized by the partnership. ...

However, as the unanticipated fugitive emissions occur within Bco’s pipeline transportation network, Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco. ...

However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...

. … When the employer completes Part 9 of the form, it should be noted that the employer does not have to ascertain in person the time that the employee will devote to work at home: the employer must simply state whether or not the employer has obliged the employee to rent an office or to use part of the employer’s home for work purposes. ...

24 June 2025 External T.I. 2025-1063501E5- Clean Hydrogen ITC- Operating Year-- summary under Operating Year Summary Under Tax Topics- Income Tax Act- Section 127.48- Subsection 127.48(1)- Operating Year periods where hydrogen continues to be produced are not disregarded The concept of an “operating year” is defined to “disregard … any period during which the project is not operating”, so that, for example, if it did not operate for one month, the operating year might be 13 months. ...

The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...

However, before concluding that “a snowmobile is … not a motor vehicle since it is not designed or equipped for use on public roads,” it stated: The first expression used, “designed or adapted” should, in our view, be used not in the sense of “capacity” but rather in the sense of “having or being organized for a specific use.” ...

Taxpayers are expected to have full access to the information pertaining to their obligations or entitlements under the ITA – and to the extent these obligations are not met, CRA will exercise the powers under the ITA to enforce compliance with tax laws and maintain the integrity of the tax system. ...

Regarding whether s. 15(2) applied, CCRA indicated that the expression "person … connected with a shareholder" in s. 15(2) may include a partnership connected with a shareholder and that, under the pre-2011 version of s. 15(2.1), a person is connected with a shareholder of a particular corporation if the person does not deal at arm's length with the shareholder, which was a question of fact. ...