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Civil Law Trust Richard Tremblay and Kim Wharram (footnote 11) summarize the most important characteristics of a civil law trust as follows: “… articles 1256 to 1298 of the new Civil Code of Quebec… now provide for a comprehensive trust regime that includes provisions for transfers of property to a trustee, and the administration of the trust property by the trustee… While this trust regime contains many concepts that are similar to common law principles relating to trusts, there are some notable distinctions. ... For Director International & Trusts Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We do not know whether XXXXXXXXXX acted pursuant to the directions of XXXXXXXXXX. 2 However, at this time, XXXXXXXXXX was the Supervisor and per Article XXXXXXXXXX of the Articles of the Foundation, only XXXXXXXXXX could have appointed a new Supervisor. 3 We did not assess the Canadian income tax consequences of the change in Beneficiaries of the Foundation. 4 However, we question whether, pursuant to the laws of the Netherlands Antilles, a person can be the Founder (i.e. ...

.), the Federal Court-Trial Division considered the meaning of the term "... an amount has become payable to a taxpayer in a taxation year... ... In Mid-West Abrasive Company, the Court looked to the surrounding words and stated: "... 'In respect of the year' refers, in my opinion, to the year during which the borrowed money was used and not the year in which the lender chose to make the request for interest... ...

Le matériel auxiliaire comprend, entre autres, les meubles et les appareils, le matériel de réparation et d'entretien et les extincteurs d'incendie. (...) 11. ... Les biens qui sont utilisés pendant plus de la moitié du temps dans le cadre d'activités de fabrication ou de transformation peuvent faire partie de la catégorie 29, 39 ou 40, selon le cas. (...) 13. ...

In this respect, La Forest, J. stated that: "... one must guard against ascribing an overly broad purpose to ss. 87 and 89. ... " LaForest, J. concluded that: "... Indians, when engaging in the cut and thrust of business dealings in the commercial mainstream are under no illusions that they can expect to compete from a position of privilege with respect to their fellow Canadians. ...

As agreed with Brian Ellis (Ellis / Wong, July 30, 2002), we do not discuss in this reply the potential avoidance issues relating to these transactions undertaken in 2000, since these issues have been referred to Tax Avoidance. ... Based on an informal discussion with the Department of Finance (Hall / Wong, July 25, 2002), this interpretation is consistent with Finance's intention that subsection 17(1) apply retroactively to any year during which the amount in question was outstanding, provided that the amount ultimately remains outstanding for more than 12 months. 3 This intention is also evidenced in the following excerpt from the Technical Notes to the 1998 Amendments: "Subject to the exceptions in new subsections (7), (8) and (9), new subsection 17(1) will apply to all amounts owing by a non-resident person to a corporation resident in Canada where at any time an amount owing has been outstanding for more than a year, or an amount owing at any time ultimately remains outstanding for more than a year, and a reasonable amount of interest has not been included in computing the corporation's income in respect of the amount owing for the portion of the corporation's taxation year during which the amount owing was outstanding. ...

Paragraph (f) of the definition of CEE. 23) Metallurgical testing – Grinding or other physical tests performed on core sample and/or bulk sample Testing of the physical material of the deposit, on or off site. ... The CIM Definition Standards for Mineral Resources & Mineral Reserves (2014) are available at: https://mrmr.cim.org/en/standards/canadian-mineral-resource-and-mineral-reserve-definitions. ...

On XXXXXXXXXX, XXXXXXXXXX announced that less than the required XXXXXXXXXX % of the XXXXXXXXXX shares had been tendered to XXXXXXXXXX 's Offer and that XXXXXXXXXX had elected to permit the Offer to expire XXXXXXXXXX. ... On XXXXXXXXXX, XXXXXXXXXX successfully acquired XXXXXXXXXX % of the shares of XXXXXXXXXX that it did not already own. ...

FIRST NATIONS WORKSHOP Pacific Region May 4- 5, 1998 Paper presented by Roberta Albert Introduction The Income Tax Rulings & Interpretations Directorate is part of the Policy and Legislation Branch. ... The Income Tax Rulings & Interpretations Directorate plays a consultative role in the Department. ...

Principal Issues: Various Indian taxation issues:- employment income- investment income- business income INDIAN ACT EXEMPTION ISSUE CONFERENCE Prairie & Pacific Regions November 20- 21, 1996 INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE Introduction The Income Tax Rulings & Interpretations Directorate is part of the Policy and Legislation Branch. ...

(footnote 1) These subsections were addressed in a comfort letter issued by the Department of Finance dated May 26, 2011, (footnote 2) which states: “93.1(5) Computing FAPI in respect of partnership — For the purpose of applying a relevant `provision in respect of a foreign affiliate [LLC2] of a taxpayer [USP] resident in Canada, if at any time the taxpayer is a partnership of which a particular corporation [Canco] resident in Canada, or a foreign affiliate of the particular corporation, is a member and if, based on the relevant assumptions, the particular corporation [Canco] and the taxpayer [USP] would be related, then (a) a non-resident corporation [USOpco] that is, at that time, a foreign affiliate of the particular corporation [Canco] is deemed to be, at that time, a foreign affiliate of the taxpayer [USP]; and (b) the taxpayer [USP] is deemed to have, at that time, a qualifying interest in respect of that foreign affiliate [USOpco] if the particular corporation [Canco] has, at that time, a qualifying interest in respect of the non-resident corporation [USOpco]. 93.1(6) Relevant provisions and assumptions — For the purposes of subsection (5), (a) the relevant provisions are… (iii) paragraphs 95(2)(a) and (g), and… (b) the relevant assumptions are that (i) the partnership is a non-resident corporation having capital stock of a single class divided into 100 issued shares that each have full voting rights, and ii) each member of the partnership (other than another partnership) owns, at any time, the proportion of the issued shares of that class that (A) the fair market value of the member's interest held, directly or indirectly through one or more partnerships, in the partnership at that time is of (B) the fair market value of all the interests in the partnership held directly by members of the partnership at that time.” ...