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When fewer items are bought during the period described in the definition of "superficial loss" than were sold during that period, the Canada Revenue Agency administratively accepts that the amount of the "superficial loss" may be determined by using the following algebraic formula: SL = (Least of S, P and B)/S x L where SL is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 61-day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...

A "qualifying amount" received by an individual in a taxation year means, inter alia, "...an amount (other than the portion of the amount that can reasonably be considered to be received as, on account of, in lieu of payment of or in satisfaction of, interest) that is included in computing the individual's income for the year and is (a) an amount (i) that is received pursuant to an order or judgment of a competent tribunal, an arbitration award or a contract by which the payor and the individual terminate a legal proceeding, and (ii) that is (A) included in computing the individual's income from an office or employment, or (B) received as, on account of, in lieu of payment of or in satisfaction of, damages in respect of the individual's loss of an office or employment, (...)." ...

In This Issue • Cancellation of Interpretation Bulletin IT-233R The Income Tax Technical News is produced by the Policy and Legislation Branch. ...

Chief- Engineering, Technical & Research Team Industrial Programs Division 580 Booth St., 18th Floor Ottawa ON K1A 0E4 ...

Project Table # 4 Wind Farm (electricity) lists the various types of expenditures which may be incurred in developing a wind farm project and identifies those which will be eligible for inclusion as CRCE, as well as those which are deductible as ordinary business expenses and those that should be capitalized as the cost of capital property. ...

(b) Paragraph 81(1)(h) states in part: "... received directly or indirectly by the taxpayer... ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...

However, we can offer the following general comments regarding the application of the Act to non-profit organizations and trusts: The Canada Customs & Revenue Agency's ("CCRA") view on some of the factors to consider when determining whether a club, society or association would qualify as a non-profit organization are contained in Interpretation Bulletin IT-496 entitled "Non-profit Organizations. ...

The response to question two at the 1993 Canadian Tax Federation Revenue Canada Round Table states in part: "... ...

We would note that comments in the above Technical Guide concerning eligible / ineligible assets of "systems" or "enhanced combined cycle systems" qualifying under paragraph (c) to Class 43.1, indicate that not all assets associated with Qualifying Equipment are considered eligible assets, i.e., not all of such assets should be considered "ancillary to" such equipment for purposes of subparagraph (a)(iv) to Class 43.1. ...