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Technical Interpretation - External summary
8 July 1992 T.I. 9210362 (January - February 1993 Access Letter, p. 5, ¶C2-017) -- summary under Subsection 2(1)
8 July 1992 T.I. 9210362 (January- February 1993 Access Letter, p. 5, ¶C2-017)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Discussion of whether an individual becomes resident at the time when he establishes permanent residence for immigration purposes. ...
Technical Interpretation - External summary
31 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2459) -- summary under Subsection 105(1)
31 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2459)-- summary under Subsection 105(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 105- Subsection 105(1) The favourable administrative position applying to personal-use property of an individual that is held by a trust will also apply where a house is owned by a trust and used by parents of a beneficiary. ...
Technical Interpretation - External summary
11 August 1993 T.I. (Tax Window, No. 33, p. 9, ¶2645) -- summary under Paragraph 6(1)(a)
11 August 1993 T.I. (Tax Window, No. 33, p. 9, ¶2645)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where the payment of insurance premiums gives rise to an employee benefit, the amount of the benefit will include sales tax on the premiums. ...
Technical Interpretation - External summary
19 May 1993 T.I. (Tax Window, No. 31, p. 12, ¶2524) -- summary under Paragraph 111(5)(a)
19 May 1993 T.I. (Tax Window, No. 31, p. 12, ¶2524)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Although an operation of oil and gas wells in Alberta following an acquisition of control would not be the same business as the operation of oil and gas wells in Saskatchewan prior to such acquisition, they would involve the sale of similar properties. ...
Technical Interpretation - External summary
25 August 1992 T.I. 921862 (April 1993 Access Letter, p. 148, ¶C117-185; Tax Window, No. 23, p. 21, ¶2146) -- summary under Subsection 143.1(1)
25 August 1992 T.I. 921862 (April 1993 Access Letter, p. 148, ¶C117-185; Tax Window, No. 23, p. 21, ¶2146)-- summary under Subsection 143.1(1) Summary Under Tax Topics- Income Tax Act- Section 143.1- Subsection 143.1(1) Athletes who have incorporated corporations to be the beneficiary of trusts established with national sports organizations will not be able to take advantage of s. 143.1. ...
Technical Interpretation - External summary
12 January 1993 T.I. (Tax Window, No. 28, p. 6, ¶2369) -- summary under Paragraph 60(b)
12 January 1993 T.I. (Tax Window, No. 28, p. 6, ¶2369)-- summary under Paragraph 60(b) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(b) Where a spouse transfers an interest in the principal residence to the other in satisfaction of alimony payments that are in arrears, no deduction generally will be available under s. 60(b) for the transfer. ...
Technical Interpretation - External summary
30 July 1992 T.I. 921871 (April 1993 Access Letter, p. 153, ¶C248-131) -- summary under Cost Amount
30 July 1992 T.I. 921871 (April 1993 Access Letter, p. 153, ¶C248-131)-- summary under Cost Amount Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Cost Amount Accounts receivable normally would be considered to be capital property, with the result that their cost amount normally would be determined under paragraph (b). ...
Technical Interpretation - External summary
19 August 1993 T.I. (Tax Window, No. 33, p.8, ¶2644) -- summary under Subsection 146(8.8)
19 August 1993 T.I. (Tax Window, No. 33, p.8, ¶2644)-- summary under Subsection 146(8.8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.8) Where the estate of the deceased is the beneficiary of an RRSP and the deceased's spouse has an interest in the RRSP only by virtue of being a life tenant under the will, s. 146(8.8) will apply to include the fair market value of the RRSP in the income of the deceased. ...
Technical Interpretation - External summary
5 April 1993 T.I. (Tax Window, No. 30, p. 19, ¶2494) -- summary under Small Business Corporation
5 April 1993 T.I. (Tax Window, No. 30, p. 19, ¶2494)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Shares which a franchisee is required to purchase in the franchisor in order to provide security in respect of trade payables which it owes to the franchisor will be considered to be used in an active business. ...
Technical Interpretation - External summary
24 July 1992 T.I. 921652 (March 1993 Access Letter, p. 75, ¶C104-041) -- summary under Subsection 107(2)
24 July 1992 T.I. 921652 (March 1993 Access Letter, p. 75, ¶C104-041)-- summary under Subsection 107(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(2) It is a question of law whether, upon the variation of a trust, the distribution of property can be said to be made under the terms of a testator's will or another trust, for the purposes of the meeting of "testamentary trust", "personal trust" and s. 248(8)(a). ...