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On this point, they differ from partnerships insofar as the latter do not have juridical personality in most countries. 2. […] 3. ... He is personally taxable only on those profits which are distributed by the company… […] 24. ... On the other hand, debt-claims participating inprofits do not come into this category (see paragraph 19 of the Commentary on Article 11); likewise interest on convertible debentures is not a dividend. […] The OECD Commentary goes further and indicates that the extended definition of “dividend” in paragraph X(3) captures economic benefits that would not generally be viewed as distributions of profit in the traditional sense: 28. ...

However, the Communiqué limits its application by not accepting "... requests for adjustments on or after October 15, 1998 where the period for filing a notice of objection has expired. ... In BJ Services, Campbell's, T.C.J., decision on this issue is as follows, at page 2043: [38] [...] ... However, once the commitment is made to proceed with the particular project all expenditures which are directly linked to the creation or acquisition of a capital asset form part of the capital cost of that asset unless that asset is not, in fact, created or acquired. [...] ...

This view is consistent with the Department of Finance Technical Notes on paragraph 95(2)(k) and (k.1) which read in part as follows: "... there has to be a transition, whether by way of the business changing its nature or by the non-resident corporation becoming a foreign affiliate of the taxpayer, in order for the fresh start rules to apply". ... The wording of paragraph 138(11.91)(e) of the Act does not mesh well with the definition of ECE in subsection 14(5) of the Act which contemplates an "... outlay or expense made or incurred by the taxpayer, as a result of a transaction... ... For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch cc Mark Turnbull ...

Therefore, Canco's EP in ECo is XXXXXXXXXX% plus XXXXXXXXXX% of XXXXXXXXXX% = XXXXXXXXXX%. ... Therefore, Canco's EP in Opco is XXXXXXXXXX% x XXXXXXXXXX% plus XXXXXXXXXX x XXXXXXXXXX% = XXXXXXXXXX%. ... Yours truly, Olli Laurikainen, CPA, CA For Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 This appears to have been paid by an entity on behalf of NR1 called XXXXXXXXXX. ...

The options had a term of XXXXXXXXXX years and vested at a rate of XXXXXXXXXX % per year. ... During the term of the taxpayer's employment the sale of the Restricted Shares was limited to XXXXXXXXXX % per year (the earliest date of sale was XXXXXXXXXX) up to a maximum of XXXXXXXXXX % of the total shares held by the taxpayer. ...

You summarize XXXXXXXXXX position as follows: "... farm property includes all property used in or suitable for farming and would include particularly property used or usable by persons for farming activities, or rented out by persons for farming activities, whether or not a business of farming is carried on on the property (for profit or otherwise). ... In this case, the particular context is to be derived by considering the entire portion of the relevant text, which is as follows: "... was in respect of the insurance of farm property, property used in fishing, or residences of farmers or fisherman". ... The following are noted. 1.Subsection 248(1) defines "home relocation loan", paragraph (b) of which reads, in part, as "the loan is used to acquire a dwelling, or... the right to inhabit a dwelling..., where the dwelling is for the habitation of the individual and is the individual's new residence" (emphasis added). 2.Subsection 248(1) defines "self-contained domestic establishment" as "a dwelling-house, apartment or other similar place of residence in which place a person as a general rule sleeps and eats" (emphasis added). 3.Section 231 defines "dwelling-house" as "the whole or any part of a building or structure that is kept or occupied as a permanent or temporary residence and includes (a)... and (b) a unit that is designed to be mobile and to be used as a permanent or temporary residence and that is being used as such a residence" (emphasis added). 4.Section 54 defines "principal residence" as "... property that is a housing unit, a leasehold interest in a housing unit or... the right to inhabit a housing unit... and... ...

EMPLOYEUR $ CAN Taux de $ US Emploi Emploi change exercé aux exercé au E.U.38/240(1) Can. 202/240 XXXXXXXXXX (USA) 88 000 1,2898 68 227 10 803 57 424 XXXXXXXXXX (T-4) 25 629 1,2898 19 871 3 146 16 725 TOTAL 113 629 1,2898 88 098 13 949 74 149 AJUSTEMENT 4 149 (4 149) TOTAL AJUSTÉ 18 098(2) 70 000(2) (1) Selon le nombre de jours. (2) Selon les renseignements figurant à la 1040. ... Conclusion En conclusion, nous résumons ci-dessous le traitement que nous préconisons relativement aux impôts versés au gouvernement américain par le contribuable sur la base des faits tels que nous les comprenons: Revenus Impôts Crédit Crédit Crédit payés accordé refusé indéter- ($ US) aux É.U. miné(1) XXXXXXXXXX 10 803 1 140 1 140 XXXXXXXXXX 3 146 332 nul 332 Ajustement 4 149 438?? ...

The CCRA's views on the appropriate treatment for tax purposes of interest rate swaps are set out in its response to question # 60 at the 1984 Canadian Tax Conference ("CTF") and again in response to question # 11 at the 1993 CTF (see also ATR-4 dated November 29, 1985) and remain unchanged. In this regard, CCRA indicated the following at the 1993 CTF: 1993 CTF Question # 11.... ...

The defined terms of the Agreement are found under Article 1 which states in part: Article 1 Definitions For the purpose of the present Agreement: [...] (a) "Organization" means the International Civil Aviation Organization, established under Article 43 of the Convention on International Civil Aviation, signed at Chicago on December 7, 1944; [...] (c) "Official of the Organization" means the President of the Council, the Secretary General and internationally recruited staff of the Organization in professional and higher categories and other staff employed by the Organization on the basis of a letter of appointment or a contract; (d) "Member States" means the States that are parties to the Convention on International Civil Aviation; (e) "Mission" means a mission of permanent character representing a Member State to the Organization, established in Canada by that State; (f) "Head of the permanent mission" means the person charged by a Member State with the duty of acting in that capacity; (g) "Premises of the mission" means the offices occupied by a mission, including the residence of the head of mission; (h) "Permanent Representative" of a Member State means the head of mission and other officers of a mission, but excluding administrative and service staff; (i) "Representative" of a Member State means a representative other than a Permanent Representative and shall include all delegates, deputy delegates, advisers and experts; [...] ...

April 3, 2002 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division Karen Power, CA T1 Taxpayer Requests (613) 957-8953 XXXXXXXXXX 2002-012642 Business Income Earned by a Status Indian This is in reply to your letter of March 1, 2002, wherein you request our views on the tax treatment of business income earned by a status Indian. ... M.N.R., 48 D.L.R. (3d) 613 at 616, Chief Justice Jackett stated that: '... as far as I know, under no system of law in Canada, does knowledge, skill or experience constitute "property" that can be the subject matter of a gift, grant or assignment... ... The provision therefore cannot apply.' To this, I would add that wages are not purchased but paid and that the result of such a proposition would affect all the departmental employees in a strange manner especially if one reads subsection 90(2) of the Indian Act, which states: 'Every transaction purporting to pass title to any property that is by this section deemed to be situated on a reserve, or any interest in such property, is void unless the transaction is entered into with the consent of the Minister or is entered into between members of a band or between the band and a member thereof.' " This case is not conclusive with respect to paragraph 90(1)(a) of the Indian Act and business income. ...