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Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? and Question 2 – Was the purpose of the payment to compensate a loss of employment? ...

S4-F14-C1- Artists and Writers-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Examples of deductible expenses of an artist such as specialized wardrobe, lessons and PD and filming and recording costs for performance (but not for study purposes) 1.38 For artists and writers, examples of deductible expenses could include: insurance premiums on musical instruments and equipment; the cost of repairs to instruments and equipment, including the cost of new reeds, strings, pads, and accessories; legal and accounting fees; union dues and professional membership dues; an agent's or mandatary's commission; remuneration paid to a substitute or assistant; the cost of makeup and hair styling required for public appearances; publicity expenses consisting generally of the cost of having photographs taken and sent with a descriptive commentary to producers, presenters, and the media, and including the cost of advertisements in publications; transportation expenses related to an engagement (including an audition) in a situation where: the engagement is out of town, in which case, board and lodging would also be allowed (see Interpretation Bulletin IT‑518R, Food, Beverages and Entertainment Expenses), a large instrument or equipment must be carried to the engagement, dress clothes must be worn from a residence to the place of engagement, or one engagement follows another so closely in time that a car or taxi is the only means by which the engagement can be fulfilled; the cost of filming or recording performances where required for their preparation or presentation; telephone and cell phone expenses, including an applicable portion of the cost of a telephone in a residence where the number is listed as a business phone; capital cost allowance (CCA) (Class 8) on instruments, sheet music, scores, scripts, transcriptions, arrangements, and equipment; CCA (Class 8) on the cost of wardrobe items acquired by an artist specifically to earn self-employment income and that is used solely for performances, when the acquisition of such items gives rise to an enduring benefit to the artist …; the cost of wardrobe items used solely for performances when there is no enduring benefit to an artist; the cost of repairs, alterations, and cleaning of clothes for the purpose of their use in self-employment, or required as a result of such use; costs to maintain that part of an artist or writer's residence used for business purposes or to rent a studio; the cost of music, acting, or other lessons incurred for a particular role or part or for the purpose of general self-improvement in an individual's artistic field; the cost of industry-related periodicals; the cost of equipment rental; art shipping expenses; and the cost of professional development activities and specialized training. 1.39 The following deductions are not allowable because they are either capital expenditures or they are personal or living expenses: the cost of musical instruments or other equipment necessary for the artist's performance (however, CCA may be deducted …); the cost of sheet music, scores, scripts, transcriptions, arrangements, other recordings, or "air checks" (again, however, see the comments in ¶1.38(l) regarding CCA); filming and recording costs incurred specifically for the purpose of study and general self-improvement (however, if the preparation or presentation of a particular performance requires that it be filmed or recorded, see ¶1.38(j)). ...

. … 1.44 Partners are not necessarily considered not to deal at arm's length with each other in transactions outside of their partnership activity merely because they are members of the same partnership Shareholders acting in concert 1.53 …[I]f a sufficient number of minority shareholders act in concert in order to direct the affairs of a corporation, they may be considered not to be dealing at arm's length with the corporation. … In a widely-held corporation, the fact that a majority of shareholders vote collectively to take some business action may not, by itself, indicate that those shareholders are acting in concert…. 1.54 [In] situations where closely-held private corporations employ some of the same personnel, occupy the same premises, and to the public eye, appear to be one enterprise…the corporations may be considered not to be dealing with each other at arm's length. ...

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S4-F7-C1- Amalgamations of Canadian Corporations-- summary under Subsection 249(3) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(3) Requirement for Amalco year end not to skip a year 1.17.1 … [A] fiscal period of a corporation can be up to 53 weeks. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 44(5)(b) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(b) Meaning of similar business 1.41 The term similar business as used in the phrase “the same or a similar business” or “from that or a similar business” in ¶ 1.33(c) is generally interpreted in a reasonably broad manner. ...

. …; amounts not characterized as a fine or penalty under the legislation imposing the particular amount ...

S3-F9-C1- Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing timing of deduction for loss from theft or embezzlement 1.38 … In cases where the allowable loss is already reflected in the reported income or loss of a business, the amount of reported income or loss will not have to be adjusted. ...

. … Contract Novation 1.9 Novation of a contract occurs when there is a substitution of a new contract for an existing one between the same or different parties. ...

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