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However, as mentioned in paragraph 13 of IT-147R3, "Capital Cost Allowance – Accelerated Write-Off of Manufacturing and Processing Machinery and Equipment", it may be difficult in some cases to determine the amount of "time" that a particular machine or piece of equipment is used in the manufacturing or processing of those goods that are for sale or lease, and those that are not for sale or lease. ...

. / Garron] v The Queen 2012 SCC 14). However, pursuant to subsection 94(3) of the Act, a trust which is otherwise factually non-resident, will be deemed to be resident in Canada if at the end of the taxation year (provided the trust exists at that date) or the time in the taxation year immediately before it ceases to exist (known as the "specified time"), there is a "resident contributor" or a "resident beneficiary", each term as defined in subsection 94(1) of the Act. ...

Carruthers, CA April 3, 2013 Dear XXXXXXXXXX: Re: Disproportionate UFT Election This is in reply to your email dated August 2, 2012, in which you inquired in what year a corporation resident in Canada should file a disproportionate underlying foreign tax ("UFT") claim pursuant to paragraph (b) of the definition of "underlying foreign tax applicable" in subsection 5907(1) of the Income Tax Regulations (the "Regulations") in the following scenario: A corporation resident in Canada ("Canco") owns 100% of the issued and outstanding shares of a foreign affiliate ("FA1") which owns 100% of the issued and outstanding shares of a second foreign affiliate ("FA2"); Each of Canco, FA1 and FA2 have a December 31, taxation year end; The exempt surplus, taxable surplus, and UFT accounts of FA1 and FA2 in respect of Canco in Year 1 prior to the payment of any dividend are as follows: Exempt Surplus Taxable Surplus UFT FA1 0 0 0 FA2 0 $200 $25 */ in Year 1 FA2 pays a $100 dividend to FA1 all of which is deemed to have been paid out of FA2's taxable surplus resulting in FA1 having a taxable surplus and UFT account in respect of Canco of $100 and $12.50, respectively; and in Year 2 FA1 pays a $100 dividend to Canco all of which is deemed to have been paid out of FA1's taxable surplus. ...

The unrestricted portion of such farm losses is limited to $2,500 plus ½ of the next $12,500 of losses. ...

These definitions include, inter alia: (c) compensation for property destroyed and any amount payable under a policy of insurance in respect of loss or destruction of property; and … (f) compensation for property damaged and any amount payable under a policy of insurance in respect of damage to property, except to the extent that the compensation or amount, as the case may be, has within a reasonable time after the damage been expended on repairing the damage. ...

Section Manager for Division Director International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Section 691(c)(1) provides that a person who includes an amount of income in respect of a decedent (“IRD”) in gross income under § 691(a) is allowed as a deduction, for the same taxable year, a portion of the estate tax paid by reason of the inclusion of that IRD in the decedent’s gross estate. ...

The interest you hold in Mutual Fund # 1 is in respect of a mutual fund trust resident in Canada. 3. ...

We also acknowledge our May 27, 2016, conversation (Robinson / XXXXXXXXXX). ...

Reasons: CRA policy as outlined in IT-530R, P102 and documents 2000-005864 & 2010- 037556. ...

& 2. Question of fact. Reasons: 1. General damages received in respect of personal injuries sustained before or after the loss of employment (i.e., in situations of harassment during employment or defamation after dismissal) will be viewed as unrelated to the loss of employment and therefore are non-taxable. ...