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., " made or incurred for the purpose of gaining or producing income from the business or property" paragraph 18(1)(a); "not an outlay... on account of capital" paragraph 18(1)(b); "reasonable in the circumstances" section 67. ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

November 4, 1996 Verification, Enforcement and Policy & Legislation Compliance Research Branch Branch Tax Incentive Audit Section J.A. ...

10 May 1993 Internal T.I. 9312927 F- Retirement Compensation Arrangement Unedited CRA Tags 207.6(2), 248(1) Retirement compensation arrangement May 10, 1993 WINNIPEG TAXATION CENTRE HEAD OFFICE Employer Services Division Financial Industries Division Lynn Ingram, Section Head Adèle St-Amour    (613) 952-1764 Attention:  Carole Roy Retirement Compensation Arrangement ("RCA") This is in response to your referral of January 19, 1993, received from Source Deductions Division on March 4, 1993. ...

1993 Internal T.I. 9328657 F- Successor Rules Re Partnership and Change of Control Unedited CRA Tags 66.7(10)(j), 96(1)   October 7, 1993 Calgary District Office Resource Industries J. ...

Szeszycki    (613)  957-8953 Deductibility of a Lump Sum Payment This is in reply to your memorandum of July 26, 1993 and further to our telephone conversations (Szeszycki/White) of October 15 and November 1, 1993, in which you requested our opinion on the deductibility of a lump sum maintenance payment made by XXXXXXXXXX to his former spouse pursuant to an amended court order. ...

Raisons POUR POSITION ADOPTÉE: Méthode non acceptée en vertu de 181(3) Table ronde CGA juin 1995 Question 17 Groupe est une société canadienne imposable qui a acquis dans le passé, les actions d'une société (ci-après "Filiale") pour environ 1 300 000 $. ...

Cloutier 7-951496 Capital Tax- Resource Profits Calculation We are writing in response to your June 2, 1995 request for our opinion on whether producers in the Oil & Gas and Mining Industries should be required to allocate provincial capital tax between resource and non-resource activities and deduct the capital tax attributed to resource activity in determining resource profits as defined in Regulation 1204. ...

Subsection 103(1) of the Act applies where the principal reason for the agreement to share profits in a certain manner ".... may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under this Act, the share of each member of the partnership in the income or loss, as the case may be,........is the amount that is reasonable having regard to all the circumstances..... ...