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Summary of Agellan Commercial REIT Circular under Mergers & Acquisitions –REIT/Income Fund/ LP Acquisitions- LP Acquisitions of Trusts. ...

These are additions to our set of 759 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¼ years of releases by the Directorate. ...

Summaries of 27 November 2018 CTF Roundtable Q. 2, 2018-0780071C6 under s. 112(3)(b)(i), s. 52(2), s. 52(3), s. 53(1)(b)(ii) and s. 89(1) – capital dividend account- (a)(i)(A). ...

These are additions to our set of 777 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ½ years of releases by the Directorate. ...

., its earnings as computed in accordance with the Country A income tax law – but that such adjustments were to be added to its earnings pursuant to Reg. 5907(2)(f), stating in its summary in the latter regard that: The money realized and retained by the foreign affiliate [i.e., Forco 1], but excluded from its income for foreign income tax purposes as a result of the corresponding adjustment by the foreign tax authority, would be "revenue, income, or profit" derived by the foreign affiliate for purposes of paragraph 5907(2)(f).... ...

., a group sickness or accident insurance plan (“GSAIP”), a private health services plan (“PHSP”), or a group term life insurance policy (“GTLIP”)) allows for the provision of benefit coverage to such individuals – although a GTLIP may only provide benefit coverage to current and former (including retired) employees. ...

Summary of 4 March 2019 Joint Committee Submission on Definition of “Public Corporation” under s. 89(1)- public corporation – para. ...

These are additions to our set of 807 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¾ years of releases by the Directorate. ...

If Y and Z argued that s. 104(13) did not apply to them because no amount was payable to them in the year, CRA would apply s. 56(2) or (alternatively) s. 105(1) to include the dividend amounts in their income – but without any s. 104(6) deduction to the Trust. ...

The only difference appears to be a purely semantic one – the s. 7 services are not given a label of, say, regulated health care service. ...