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These are additions to our set of 3,215 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

Summary of 28 May 2025 IFA Roundtable, Q.5 under s. 95(1) – FAT. ...

These are additions to our set of 3,227 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

., government contributions exceed plan holder contributions, annual withdrawals are limited to 10% of the value in the RDSP at the beginning of the year – except that CRA has indicated that it may permit withdrawal requests above that limit in circumstances of financial hardship where it is just and equitable to do so. ...

Revised summaries of GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 under ETA s. 188.2(5) and s. 123(1) – consideration. ...

Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in unsuccessful attempt to maintain child support were deductible 28 April 2000 External T.I. 2000-0020695 F- CREDIT-BAIL Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Construction Bérou not followed after 1990 – taxpayers generally should follow the legal form of the agreement General Concepts- Substance CRA generally assumes that the form of the agreement reflects the relationship ...

There is not considered to be such a right where the shareholders’ agreement for a corporation carrying on a franchised operation (“Franchisee”) specifies that in the event that the individual manager of Franchisee (who holds 50% of Franchisee’s commons shares) departs, the other 50% common shareholder (the Franchisor) has the mandate to find a third party to purchase the manager’s shares – or that, in such event, the manager’s shares are to be automatically redeemed by Franchisee. ...

Summaries of Joint Committee, Submission letter entitled “Technical Amendments Package of September 16, 2016" dated 15 November 2016 under s. 87(8.4), s. 90(6.1), s. 91(4.6)(b), s. 91(1.2), s. 91(1.1). s. 91(1.5), s. 212.3(2), s. 212.3(7). s. 212.3(18), s. 212.3(9)(b), s. 219.1(3)(c). s. 248(1) – derivative forward agreement, Reg. 6204(1)(b). ...

The Queen, 2017 TCC 13 under General Concepts – Agency, ETA s. 153(1), s. 232(3). ...

Treaty, that Article requires that the transfer to the spousal trust be made under a will – which is often a problem because US individuals often use an inter vivos trust to reduce or defer US estate tax. ...