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J1 & J2 also claimed the available small business deduction for their respective incomes;? ... It billed JVCo on the basis of "cost of materials and labour + XXXXXXXXXX%". ... Management Fees to J1 & J2 The amount of the management fees paid by JVCo to J1 & J2, in order to get JVCo's income below $200,000, would have had to have been reasonable in the circumstances (section 67 of the Act) in order for JVCo to be allowed to expense the amount. ...

In respect of cultivated lands, $XXXXXXXXXX per acre amount will be paid where construction of the XXXXXXXXXX takes XXXXXXXXXX. d) Nuisance & Inconvenience (Disturbance)- The Agreement provides that XXXXXXXXXX will pay XXXXXXXXXX compensation for other losses and damage of any nature or kind, based on a XXXXXXXXXX amount of $XXXXXXXXXX. 4. ... We note that the definition of "restrictive covenant" in proposed subsection 56.4(1) of the Act is broadly worded as follows: ""restrictive covenant", of a taxpayer, means an agreement entered into, an undertaking made, or a waiver of an advantage or right by the taxpayer (other than an agreement or undertaking for the disposition of the taxpayer's property or — except where the obligation being satisfied is in respect of a right to property or services that the taxpayer acquired for less than its fair market value — for the satisfaction of an obligation described in section 49.1 that is not a disposition), whether legally enforceable or not, that affects, or is intended to affect, in any way whatever, the acquisition or provision of property or services by the taxpayer or by another taxpayer that does not deal at arm's length with the taxpayer." The new rules in proposed section 56.4 of the Act do not merely address non-competition agreements or other covenants granted in the course of carrying on a business: the definition of a "restrictive covenant" is broad enough to include an "agreement entered into, an undertaking made or a waiver of an advantage or right by the taxpayer … whether legally enforceable or not. ...

To reflect this change, please substitute the responses to "Question 2" and "Questions 3, 4 & 6", respectively, of our February 11, 2002 letter with the following. ... Questions 3, 4 & 6 Subsection 107(2) provides rules that apply when a "personal trust" distributes its properties, including capital properties, in complete or partial satisfaction of a capital beneficiary's interest. ...

FACTS & ASSUMPTIONS 1. ACo is a public corporation, the shares of which are traded on the XXXXXXXXXX Stock Exchange. ... Paragraph 40(3.4)(b) provides: (3.4) Loss on certain properties — If this subsection applies because of subsection (3.3) to a disposition of a particular property,... ...

FORP has used all capital contributions by the members / partners to provide debt financing, at interest, to affiliated companies within the Parent corporate group. In turn, the affiliated companies have applied the loan proceeds to active business activities and / or investments that produce / generate active business income. ... In this regard, we note that in Advance Income Tax Ruling # 2006-0187681R3, issued in 2007, the Rulings Directorate concluded that the Sameignarfelag discussed in that ruling would qualify as a partnership for purposes of the Act. ...

FACTS & ASSUMPTIONS 1. BCo is a corporation formed under the laws of XXXXXXXXXX. ... Lastly, it is helpful to revisit subsection 87(8.1) and the definition of foreign merger: “For the purposes of this section, "foreign merger" means a merger or combination of two or more corporations each of which was, immediately before the merger or combination, resident in a country other than Canada …. to form one corporate entity resident in a country other than Canada … in such a manner that, and otherwise than as a result of the distribution of property to one corporation on the winding-up of another corporation…”. ... R., 2009 DTC 5093, made the following comments regarding the overall scheme of the legislation and subsections 40(3.3), 40(3.4) and 40(3.5), at paragraph 34: “[…] in light of the overall scheme of the legislation and of the provision in question, they should be seen as establishing a stop-loss rule. ...

Facts & Submission The Taxpayer died on XXXXXXXXXX. Her Will deals with the residue of the Estate, establishing 3 testamentary trusts for her Children, their spouse and issue (Trust1, Trust2 and Trust3). ... Monthly payments of $ XXXXXXXXXX were made by Child3 to Child1 "In Trust" from XXXXXXXXXX to XXXXXXXXXX. In XXXXXXXXXX, the monthly rental income of $ XXXXXXXXXX was included in the Trusts' T3 returns. ...

[Emphasis added] […] As you indicate, Interpretation Bulletin IT-174R states in paragraph 1 that the term “capital cost of property” generally means the full cost to the taxpayer of acquiring the property. ... R, 2013 DTC 5085, (SCC) (“ Daishowa ”) as:[39] A contingent liability is “a liability which depends for its existence upon an event which may or may not happen”: Canada v. ... Inland Revenue Commissioners, [1963] A.C. 235 (H.L.), at p. 262. […]. ...

FACTS Based on the documentation enclosed with your letter, we understand the facts to be as follows: Articles & Memorandum of the Association: The Association was incorporated as a non-share corporation under XXXXXXXXXX of XXXXXXXXXX on XXXXXXXXXX. ... HMQ, 84 DTC 6040 (" Gull Bay ") turns on this point. Gull Bay was a corporation that was wholly-owned by the Gull Bay Indian band; its objectives included improving the social and economic conditions of members of the band. ...

Betty Reid HEADQUARTERS First Nations Section Eliza Erskine Audit Division (613) 274-3022 Northern BC & Yukon TSO 2008-027186 Taxation of Payment to Nisga'a Citizen from Nisga'a Lisims Government We are writing further to our email discussions with you of March 18, 2008 (Reid/Erskine), regarding a telephone inquiry to us from a tax preparer seeking to determine whether a particular payment from the Nisga'a Lisims Government to a Nisga'a citizen not resident on a reserve or former reserve would be exempt from tax. ... Relevant Agreements & Legislation The NFA is a "treaty and a land claims agreement" and is intended to be a final settlement of "aboriginal rights, including aboriginal title, in Canada of the Nisga'a Nation" (Ch.2, paras. 1 and 22). ...