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These are additions to our set of 2,958 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 23 ¼ years of releases of such items by the Directorate. ...

Since the cost to him of the passenger vehicle (a designated immediate expensing property per Reg. 1104(3.1)) was higher than the Reg. 7307(1) limit, s. 13(7)(i) provided that the proceeds of disposition were computed as: $38,000 X $34,000/ $50,000 = $25,840, resulting in recapture of depreciation. ...

These are additions to our set of 2,984 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 23 ¼ years of releases of such items by the Directorate. ...

Summary of 21 October 2024 External T.I. 2024-1027501E5 under Reg. 1100(2)(A), s. 127(9) – government assistance and s. 13(1). ...

These are additions to our set of 3,017 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 23 ½ years of releases of such items by the Directorate. ...

Summary of 3 December 2024 CTF Roundtable, Q.14 under s. 129(4) – “income” or “loss”. ...

These are additions to our set of 3,053 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 23 ¾ years of releases of such items by the Directorate. ...

Langlois, which found that a 50% shareholder who had “an operational role, not a decision-making role” was not part of the de facto control of the corporation, whereas the other shareholder, who “[a]s the sole director … had the power that ensured him a dominant influence in the direction of the [corporation]” had de facto control. ...

Summary of Joint Committee, Federal Budget 2024 – Capital Gains Inclusion Rate, 22 January 2025 Joint Committee submission under s. 38(a). ...

In finding that s. 152(4)(b)(vii) did not authorize CRA to reassess the trust within three years of the expiry of the normal reassessment period to adjust the proceeds of disposition, the Directorate indicated: The relevant scoping condition in s. 152(4)(b)(vii) – that the assessment was “to give effect to the application of section 94”- meant “to cause section 94 to apply.” ...