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Cette situation se rencontre dans certains États à l'égard de personnes physiques, notamment les agents diplomatiques et les fonctionnaires consulaires étrangers en service sur leur territoire. [...] ...

The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. [...]. ...

Prior to the December 2007 amendments, the Expenditure Deductible Condition read as follows (emphasis added): “expenditures … that are or would, if the partnership were a foreign affiliate of the taxpayer, be deductible in the year or a subsequent taxation year by the other affiliate or the partnership in computing the amounts prescribed to be its earnings or loss from an active business” The December 2007 amendment to “old” clause 95(2)(a)(ii)(B) was part of a large package of proposed amendments to the Act released by Finance on October 2, 2007 and, in our view, that amendment was a tightening measure consistent with the repeal of “old” clause 95(2)(a)(ii)(A) which had been proposed in Budget 2007 and implemented by the same December 2007 amendments. ...

APPLICATION DE L'ARTICLE 31 DE LA LOI Puisqu'il n'y a pas d'espoir raisonnable de profit, nous sommes d'avis que les contribuables ne peuvent invoquer l'article 31 pour réclamer une déduction allant jusqu'à 5 000 $. ...

Chouinard A/Section Chief Business, Property & Employment Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Le paragraphe 2d) du Bulletin d'interprétation IT-487 stipule que notre interprétation des mots "... de l'entreprise... ...

April 29, 1998 Federal Provincial Relations HEADQUARTERS & First Nations D. ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 6- ...

In particular, subparagraph 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that "... can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) an outlay or expense". ...

Following the decision in the Williams case and as a result of a letter issued by the Department on December 29, 1992, which was followed up with considerable input from the Indian community, the Department has developed " INDIAN ACT EXEMPTION FOR EMPLOYMENT INCOME DETAILED GUIDELINES" which were released on December 15, 1993. ...