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Reasons: See file # 970516, 963605, and 931300. Subsection 256(1) of the Act refers to “corporation”, not a Canadian controlled private corporation. ...

Principal Issues: Whether compensation (similar to commission) called a trailer fee to an investment manager for acquiring third party investment passed on to his investor clients whose investments are held in trust would be included in income pursuant to paragraph 12(1)(x) & subsection 12(2.1)? ...

Subsection 248(1) defines “salary or wages” as “... the income of a taxpayer from an office or employment as computed under subdivision a of Division B of Part I...”. ...

Reasons: See Q.13 of file # 5-2830 and IT-508R, Death Benefits. Subsection 248(1) of the Act defines death benefits. ...

For more information on motor vehicle allowances, go to canada.ca/automotor-allowances or see Chapter 2 of Guide T4130, Employers’ Guide – Taxable Benefits and Allowances, which is available on the CRA website at www.cra-arc.gc.ca. ...

During 1993, the Department met with many interested parties concerning the taxation of Indians and with input from the Indian community has developed " INDIAN ACT EXEMPTION DETAILED GUIDELINES". ...

The "where" condition in (b) would be present if, "... the former property was used by the taxpayer or a person related to the taxpayer for the purpose of gaining or producing income from a business". ...

Le Petit Robert définit le terme «volontaire» comme suit: « qui résulte d'un acte de volonté (et non de l'automatisme, des réflexes ou des impulsions). ...

File # 932993 Principal Issues: Whether an annual pay out amount from a RRIF with a 5 year term is a "periodic pension payment" as defined in section 5 of the ITCIA and under paragraph 2(a) of Article XVIII of the Canada-US Convention. ...

You describe a situation where an individual owns 100 % of the outstanding shares of a corporation. ...