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& 2. Benefits funded under the EI Act will generally be taxable under 56(1)(r) of the Act. ... Our Comments Questions #1 & #2 Benefits Funded Under the EI Act: In our view, all payments/allowances received by individuals or paid directly to educational institutions in the above situation, which are funded under the EI Act, would be taxable under paragraph 56(1)(r) of the Income Tax Act (the "Act"). ...

Subparagraph 152(4)(b)(iii) of the Act states: (4) Assessment and reassessment [limitation period]- The Minister may at any time make an assessment, reassessment or additional assessment of tax for a taxation year, interest or penalties, if any, payable under this Part by a taxpayer or notify in writing any person by whom a return of income for a taxation year has been filed that no tax is payable for the year, except that an assessment, reassessment or additional assessment may be made after the taxpayer's normal reassessment period in respect of the year only if [...] (b) the assessment, reassessment or additional assessment is made before the day that is 3 years after the end of the normal reassessment period for the taxpayer in respect of the year and [...] ... QUESTION 4 & 5: IF THE TRUST IS NOT A HEALTH AND WELFARE TRUST, WHAT PROVISIONS OF THE ACT CAN BE RELIED UPON TO DISALLOW THE CONTRIBUTIONS? ...

Analysis – deductibility of the dividend under subsection 91(5) A. S Corporation is XXXXXXXXXX% owned by Canadian Resident after the expiry of Agreement In order for Canadian Resident to claim a deduction under subsection 91(5), the following conditions of that provision need to be met: Where in a taxation year a taxpayer resident in Canada has received a dividend on a share of the capital stock of a corporation that was at any time a controlled foreign affiliate of the taxpayer, there may be deducted, in respect of such portion of the dividend as is prescribed to have been paid out of the taxable surplus of the affiliate, in computing the taxpayer's income for the year, the lesser of (a) the amount by which that portion of the dividend exceeds the amount, if any, deductible in respect thereof under paragraph 113(1)(b), and (b) the amount, if any, by which (i) the total of all amounts required by paragraph 92(1)(a) to be added in computing the adjusted cost base to the taxpayer of the share before the dividend was so received by the taxpayer exceeds (ii) the total of all amounts required by paragraph 92(1)(b) to be deducted in computing the adjusted cost base to the taxpayer of the share before the dividend was so received by the taxpayer. ... Subsection 92(1) reads as follows: In computing, at any time in a taxation year, the adjusted cost base to a taxpayer resident in Canada of any share owned by the taxpayer of the capital stock of a foreign affiliate of the taxpayer, […] (b) there shall be deducted in respect of that share (i) […], and (ii) any dividend received by the taxpayer before that time, to the extent of the amount deducted by the taxpayer, in respect of the dividend, under subsection 91(5) [the amount of the dividend is deemed by the Agreement to have been deducted under that provision but no such dividends were paid] in computing the taxpayer's income for the year or any preceding taxation year (or that would have been deductible by the taxpayer but for subsection 56(4.1) and sections 74.1 to 75 of this Act and section 74 of the Income Tax Act, chapter 148 of the Revised Statutes of Canada, 1952). ...

2 March 2011 Internal T.I. 2011-0392001I7- Qualifying Period- OETC- 122.3(1) Unedited CRA Tags ITA: 122.3(1) Principal Issues: Scenarios 1 & 2: What is the number of days of eligibility for the OETC? ... ISSUES: Based on the scenarios presented above, you ask the following questions: Scenarios 1 & 2: What is the number of days of eligibility for the OETC? ...

Harold Silvester, John Wiley & Sons Canada Limited Page 743 “Appropriations (also called reserves) of retained earnings are nothing more than segregations of retained earnings, temporarily or perhaps even permanently established for a given purpose. ... Appropriations and restrictions: Appropriation for investment in plant $ 15,000 Restriction for bond sinking fund 25,000 Unappropriated retained earnings 126,000 Total retained earnings 166,000 A 1997 survey of annual reports of 200 Canadian public companies for 1995 and 1996 was prepared by Clarence Byrd and Ida Chen entitled Financial Reporting in Canada, Twenty-second Edition, and was published by the CICA. ...

Fraudulent Investment Schemes – Basic Tax Rules This document provides information for situations where taxpayers are involved in a fraudulent investment scheme ("Scheme") including ponzi or ponzi-like schemes. ...

Compliance Programs Branch – Specialty Audit Division Position Your view is that the payment of an amount in respect of a "restrictive covenant" does not represent business income and cannot be considered to be profits from a business as purported by the Representative. ...

Facts & Submission A taxpayer passed away on XXXXXXXXXX. The value of the taxpayer's estate was $XXXXXXXXXX and included money ($XXXXXXXXXX of which was distributed to a nephew and a niece of the deceased) and a personal-use property which was the principal residence of the deceased taxpayer (the inherited residence). ...

Withholding & Reporting Paragraph 153(1)(g) of the Act requires that every person paying fees, commissions or other amounts for services shall deduct or withhold from the payment the amount determined in accordance with prescribed rules. ...

Reassessment Period / Article XXVII(3) of the Barbados Convention It appears that the transfer by XXXXXXXXXX of the U.S. rights to XXXXXXXXXX to XXXXXXXXXX is a transaction between the taxpayer (XXXXXXXXXX) and a non-resident person with whom the taxpayer was not dealing at arm's length (XXXXXXXXXX). ... As we have stated in the past (see, for example, documents #XXXXXXXXXX and # 2000-0047365), an IBC incorporated in Barbados would be a resident of Barbados for purposes of the Barbados Convention but for Article XXX(3) of that Convention and therefore would satisfy the test in paragraph 5907(11.2)(c) of the ITR since such an IBC is liable to tax in Barbados on its worldwide income (albeit at lower rates). ...