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23 August 2001 External T.I. 2001-0086235 F- CONVENTIONS FISCALES A.18-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 QPP and OAS were pension payments made under social security legislation for purposes of the Slovenia and Croatia treaties Regarding the tax treatment of QPP and OAS payments made to residents of Slovenia, Croatia and Germany, CCRA indicated that: Under the Slovenia Convention, since “pension” was not defined, its meaning under s. 5 – pension – (a)(ix), of the ICTCIA applied to render them pension payments. ...

However … this Bulletin was not intended to be used by taxpayers to change the legal nature of their contracts. … [T]he question of whether a contract is a lease agreement or a contract of sale should be resolved on the basis of the legal relationships created by the terms of an agreement, rather than by an assessment of the underlying economic reality (as indicated by GAAP). ...

. … … [T]he question of whether a contract is a lease agreement or a contract of sale should be resolved on the basis of the legal relationships created by the terms of an agreement, rather than by an assessment of the underlying economic reality (as indicated by GAAP). ...

10 January 2002 External T.I. 2001-0090325 F- UTILISATION DES VEHICULES-- summary under Subsection 6(2) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(2) commuting in connection with employer requirement to keep vehicle overnight at home was personal use – but not emergency use Outside normal working hours, management employees of a municipality are required to park the automobiles used in its day-to-day operations at their homes for use in quickly responding to emergencies situations such as water leaks or fires. ... Consequently, it is recommended that the employer and employees keep a record of the use of the motor vehicle to clearly distinguish between kilometres driven for personal purposes and kilometres driven for business purposes …. ...

. … We consider that the amount is determined when it is sufficiently determinable or where it can be reasonably estimated. … [T]he increases in a pharmacist-owner's fees for services for the period from January 1, 1999 to May 31, 2001 are amounts receivable as of June 1, 2001 and... they must be included in the computation of the pharmacist-owner's income in the taxation year that includes June 1, 2001. ...

Finally, for purposes of calculating the … paragraph 118(1)(b) [credit], the individual must take into account the dependant's net income. ... In addition … monthly CSST benefits are also part of the dependant's net income, even if those benefits are deducted in computing the dependant's taxable income. ...

. … [T]he pharmacist may become entitled to receive the full price of the goodwill, in your example $750,000, so that the taxpayer must include this full amount under paragraph (a) of Variable E of CEC in the taxation year of the sale of the goodwill. … CCRA went on to note that if there was a subsequent downward adjustment to the purchase price, a corresponding deduction generally would be available under s. 24(1)(a). ...

. … [A] taxpayer does not necessarily have to have an overall economic benefit or an increase in net worth for subsection 15(1) to be applicable in a particular situation. Thus …any decrease in the fair market value of the Class A shares of the capital stock of Opco should not be taken into account in determining the value of the benefit that would be conferred on Portfolioco …. ...

Regarding the likely nonapplication of s. 56(2) respecting such dividends, CCRA stated: [I]n the absence of a sham … and to the extent that sufficient consideration was given for the shares at the time they were issued, subsection 56(2) would generally not apply to dividend income since, until a dividend is declared, the profits belong to the corporation as retained earnings. ... [See …] Neuman and McClurg.... ...

. … [and] these years can be before the effective date of the amendments to section 120.4. … [A]ssuming Ms. ...