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The disposition of a leasehold interest is discussed in Interpretation Bulletin IT-464R, Capital Cost Allowance – Leasehold Interests. ...

It is our understanding that the Bankruptcy and Insolvency Act (the " BIA") provides that a secured creditor takes priority over any unsecured creditors, including an unsecured claim by the Minister for federal income tax. 2. ...

.” The court also said, “The plain meaning of s. 20(1)(c)(i) does not support an interpretation of ‘income’ as the equivalent of ‘profit’ or ‘net income’ …. ...

These guidelines, along with some others, are explained in the Canada Revenue Agency's (the "CRA") Interpretation Bulletin IT-128R, "Capital Cost Allowance – Depreciable Property", at paragraph 4. ...

Therefore, paragraphs 149(1)(d.5) and subsection 149(1.3) interact to require the entity to meet two distinct tests – the capital ownership test and the shareholder votes test. ...

.: IT 87-R2, "Policyholders – Income from Life Insurance Policies", paragraph 18. ...

Affordable Housing Providers – Other Exemptions Affordable housing providers may be exempt from tax under the following sections of the Act that do not have the same requirements and restrictions imposed by paragraph 149(1)(l): Municipal corporations are exempt from tax under paragraph 149(1)(d.5) provided at least 90% of the capital is owned by municipalities or public bodies performing a function of government. ...

Paragraph 7 of Interpretation Bulletin IT-81R, Partnerships – Income of Non-Resident Partners confirms that where a partnership is deemed pursuant to paragraph 212(13.1)(b) to be a non-resident person, the withholding applies to the full amount of the payment even though some members of the partnership are residents of Canada. ...

The amount, if any, determined by the formula A – B in paragraph 17.1(1)(b) ITA is to be included in the CRIC's income for a taxation year. ...

., generally 90% or more) of the fair market value of the property owned by the corporation was attributable to": (a) property that has been used by (i) the corporation or any other corporation, a share of the capital stock of which was a share of the capital stock of a family farm corporation of the person or of a spouse, common-law partner, child or parent of the person, (i.1) a corporation controlled by a corporation referred to in subparagraph (i), (ii) the person, (iii) the spouse, common law partner, child or parent of the person, … principally in the course of carrying on a farming business in Canada in which the person or a spouse, common-law partner, child or parent of the person was actively engaged on a regular and continuous basis (or, in the case of property used in the operation of a woodlot, was engaged to the extent required by a prescribed forest management plan in respect of that woodlot), (b) shares of the capital stock or indebtedness of one or more corporations all or substantially all of the fair market value of the property of which was attributable to property described in paragraph (c), or (c) properties described in paragraph (a) or (b).” ...