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We also assume that as an employee of this company, XXXXXXXXXX ' work was related to the above-noted offshore activities of his employer. ... It appears to us that Article 27A(4) of the UK Convention could apply in XXXXXXXXXX ' situation. ...

The collaborations may be in the form of a partnership, joint venture or contractor / sub-contractor relationship. ... Contractor / Sub-contractor arrangement- The applicant contractor would include the Grant in income in the year it is received. ...

(maintained friendly relationships). [...] 4. preserve or provide for the preservation of (a building, machine, road, etc.) in good repair. ... To continue in possession of (property, etc.). [...] 4. To care for (property) for purposes of operation productivity or appearance; to engage in general repair and upkeep. ...

The formula is A- (B + C) where: A. is the total of all support amounts paid after 1996 and before the end of the year by the payer to the recipient, where the payer and the recipient were living separate and apart at the time the support amount was paid; B. is the total of all child support amounts payable by the payer to the recipient under an order or agreement on and after its commencement day and before the end of the year, for a period that began on or after its commencement day; and C. is the total of all support amounts paid by the payer to the recipient after 1996 that were deductible in computing the payer's income for a preceding year. ... The Queen, 2004 DTC 3300, at page 3309, determining whether a child is a "child of the marriage" is not an easy task: "However, the issue of whether one remains "a child of the marriage" in accordance with the Divorce Act can be a tricky issue to resolve and will- in most cases, barring consent- require a decision by a competent tribunal. [...] ...

Principal Issues: In a situation where corporations, each controlled (de jure and de facto) by a different corporation, own an interest in a general partnership varying between 7% and 24 %; whether one of the corporations could become associated to one or more of the others, pursuant to subsection 256(1), if one of the corporations increased its interest in the partnership to 25% or more? ... Votre question et votre position Vous désirez savoir si une des sociétés opérantes pourrait devenir une "société associée" à une ou plusieurs des autres sociétés opérantes, en vertu du paragraphe 256(1) de la Loi, si elle augmentait le pourcentage de sa participation dans la SENC à 25 % ou plus? ...

Reasons: May be associated under paragraphs 256(1)(b), (c), (d) & (e) where de facto control exists. 2001-010474 XXXXXXXXXX Karen Power, C.A. (613) 957-8953 October 25, 2001 Dear XXXXXXXXXX: Re: Section 256- Associated Corporations This is in reply to your letter dated October 4, 2001, wherein you requested our views concerning the application of subsection 256(1) of the Income Tax Act (the "Act") in the circumstances described below. ... For situations A & B you have asked for our comments on whether Aco and Bco are associated pursuant to subsection 256(1) of the Act. ...

M.N.R. ([1991] 1 CTC 2214) the Tax Court of Canada, in discussing the purpose of subsection 112(2.1) of the Act, stated at page 2238: "... ... The use of the phrase "... in the ordinary course of business..." is designed to distinguish the exceptional situations where subsections 112(2.1) and 258(3) should not be applied from those where these subsections of the Act should be applied. ...

Membership The current membership of the GAAR Committee is: Roy Shultis, Chairman, Deputy Assistant Commissioner, Income Tax Rulings Directorate Paul Lynch, Secretary (replacing Ted Harris), Manager, Corporate Financing Section Michael Hiltz, Brian Darling, Rick Biscaro and Marc Vanasse, Directors in the Income Tax Rulings Directorate, are members with respect to their specialty area Ed Gauthier, Deputy Assistant Commissioner, GST Rulings Directorate Wayne Adams, Director, Legislative Policy Division Walter Szyc, Director, Tax Avoidance Division, Compliance Programs Branch (currently replaced by Ranjeet Nanner) Sharon Gulliver and Peter Dunn, Managers, GAAR & Technical Support Sections, Tax Avoidance Division Shaun Harrington, Counsel, Department of Justice (recently replacing John Bentley) Gerard Lalonde, Assistant Director, Tax Legislation Division, Department of Finance Patrick Boyle (Fraser Milner Casgrain), Tax Counsel Interchange • Mr. ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ... In the situations you describe, Guidelines 2 & 4 would not apply to exempt your employees' employment income, as the employer is not resident on a reserve. ...

Principal Issues: 1.Taxpayer enquiry on whether existing shares & proposed replacement shares will qualify for the "small business investment deferral" where original shares are shares of farming corporation and replacement shares are a "XXXXXXXXXX " corporation. ...