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Chief Services, Public Utilities & Exempt Corporation Section Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Le Bulletin d'interprétation IT-486R, daté du 31 décembre 1987, intitulé "Transferts entre générations d'actions d'une corporation exploitant une petite entreprise" mentionne ce qui suit aux paragraphes 5 et 6: Paragraphe 5: "... ...

An example, which you supplied, explains further: Net Income before tax, $1,500,000 Bonuses and interest on A's advances (260,000) Less: Bonus to 8 20% (1,500,000- 200,000) Interest to A on advances (120,000) (say 12% x ($1,500,000) Bonus to A- (80% x (1,5000,000- 200,000))-120,000 (920,000) Net Income before tax $ 200,000 You question whether the bonuses are deductible in the year of accrual and whether the amendments to section 12 of the Income Tax Act ("the Act") apply to interest paid on shareholder advances. ...

Payments made to facilitate the re-leasing of that space, whether to the same tenant or a new tenant, may be either deducted in the year in which the expense is incurred, or deferred and amortized to income over the term of the related lease. (* What law? ...

Otherwise, we would not consider that "... that business was carried on... ...

We would suggest you insert the reference to paragraph 110(l)(f) after the words "... any amounts rolled into an IRA. ...

It is our view that the expression "... at the time the agreement was made", as contained in subparagraph 110(1)(d)(iii) of the Act, refers to the date on which the corporation unilaterally undertakes to sell or issue the shares of its capital stock. ...

Paragraph 1(c) of Article 1 of the Nato Agreement defines "civilian component" to mean " civilian personnel accompanying a force.... ...

Until recently the Department's position has been that this instalment interest element was not deductible in calculating income either as an interest expense or as a pension contribution deductible in accordance with the provisions of paragraphs 8(1)(m) and 60(j) of the Income Tax Act (the Act). 19(1) filed a notice of objection for the taxation years " 1986 and onward" and has supplied to the courts for an extension of time in order to have his objection considered. ...

We have not examined the printout entitled "Masterplan & Your Retirement with a RCA" which was attached to your letter and make no comments as to whether its illustration of the operation of the refundable tax account is accurate. ...