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Alain Godin, Manager International & Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

En effet, lorsqu'un employé reçoit à l'avance un salaire, le montant reçu doit être inclus dans son revenu conformément au paragraphe 5(1) de la Loi de l'impôt sur le revenu (ci-après la " Loi ") dans l'année où il est reçu. ...

Les états financiers de Gesco indiquent un capital-actions émis et payé de XXXXXXXXXX $ à l'égard de XXXXXXXXXX actions ordinaires. ... Les représentants (le conjoint de Mme A et l'ex-conjoint de Mme B) ont indiqué que, malgré que Mme A et Mme B ont fourni XXXXXXXXXX $ chacune pour l'acquisition des actions de Gesco au nom de Aco et Bco respectivement, la décision de ne pas divulguer ces renseignements dans les livres des Sociétés a été prise dans le but d'éviter un éventuel conflit avec l'Ordre. ...

October 17, 2000 Audit Directorate HEADQUARTERS Small & Medium Enterprise David Shugar Division 957-2134 Attention: Diane Favel 2000-004948 Indian Exemption- Employment Income Guidelines This is in response to your correspondence of September 25, 2000, enquiring about Canada Customs and Revenue Agency's (the CCRA) position regarding the evaluation of factors connecting personal property to a reserve. ... In your correspondence you referred to the following answer given to a question from the Department of Fisheries & Oceans: Question 6: If an Indian Fisher incorporates his fishing business and becomes an employee of the corporation, would the employment income received by the Indian Fisher be exempt from taxation? ...

In the present case it remains to be determined whether: the facts (once the type and nature of the TIPs have been established) support a finding (using the guidelines set out in Appeals Decision # 95) that the tenant inducement payments are deductible as running expenses; and XXXXXXXXXX qualifies for this administrative concession regarding taxpayer requested adjustments. ... If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...

Three different categories of contributions are contemplated – Basic Annual Contributions, Deficiency-Makeup Contributions and Balloon Contributions. ... The $100 minimum is necessary to comply with the requirements set out in paragraphs 6 and 8 of IT-280R Employees Profit Sharing Plans – Payments Computed by Reference to Profits. ...

The Taxpayer designated – in its return of income for the taxation year that ended on XXXXXXXXXX – the following capital property pursuant to paragraph 111(4)(e): Class 12: intellectual property; XXXXXXXXXX Class 14.1: customer relationship XXXXXXXXXX Class 14.1: goodwill. ...

Rulings on Formula-Based Appreciation Plans will no Longer be Considered (footnote 2) ITRD will no longer consider any ruling requests pertaining to whether any given formula-based appreciation plan is a SDA, unless: i) the plan is of a type described in ATR-45 – “Share Appreciation Rights Plan” (discussed later in this memorandum); or ii) the ruling request pertains to whether one of the enumerated exceptions listed in the definition of SDA apply to the plan. ... ATR-45 SAR Plans Any reference to formula-based appreciation plans in this memorandum excludes share appreciation rights (“SAR”) plans of the type described in ATR-45 – “Share Appreciation Rights Plan”, which has the following characteristics: The unit has no intrinsic value at the date of grant; The value of a unit is not guaranteed and may have a negative value after the date of grant; and The value of each unit at any particular time is determined by subtracting the FMV of a share of the employer at the date of grant from the FMV of a share of the employer at that particular time. ...

December 16, 2019 XXXXXXXXXX- International and Large HEADQUARTERS Business Case Manager Income Tax Rulings and XXXXXXXXXX – Large Case File Auditor Directorate R. ... Subsections 2(1) (Definitions) and 3(1) (Application), and sections 8.1 (Duality of legal traditions and application of provincial law) and 8.2 (Terminology) of the federal Interpretation Act provides: Definitions 2(1) In this Act, Act means an Act of Parliament; … enactment means an Act or regulation or any portion of an Act or regulation; Application 3(1) Every provision of this Act applies, unless a contrary intention appears, to every enactment, whether enacted before or after the commencement of this Act. ...

Modified subsection 94.1(1) reads as follows (the modifications are in square brackets): 94.1 (1) If in a taxation year a taxpayer holds or has an interest in property (referred to in this section as an "offshore investment fund property") (a) that is a share of the capital stock of, an interest in, or a debt of, a non-resident entity (other than a controlled foreign affiliate of the taxpayer or a prescribed* non-resident entity) or an interest in or a right or option to acquire such a share, interest or debt, and (b) that may reasonably be considered to derive its value, directly or indirectly, primarily from portfolio investments of that or any other non-resident entity in […] and it may reasonably be concluded, having regard to all the circumstances, including […] (d) the extent to which any income, profits and gains that may reasonably be considered to be earned or accrued, whether directly or indirectly, for the benefit of any non-resident entity are subject to an income or profits tax that is significantly less than the income tax that would be applicable to such income, profits and gains if they were [earned by the person resident in Canada in respect of whom the taxpayer is a foreign affiliate], and (e) the extent to which the income, profits and gains of any non-resident entity for any fiscal period are distributed in that or the immediately following fiscal period, that one of the main reasons for the taxpayer acquiring, holding or having the interest in such property was to derive a benefit from portfolio investments in assets described in any of subparagraphs (b)(i) to (ix) in such a manner that the taxes, if any, on the income, profits and gains from such assets for any particular year are significantly less than the tax that would have been applicable under this Part if the income, profits and gains had been [earned by the person resident in Canada in respect of whom the taxpayer is a foreign affiliate], there shall be included in computing the taxpayer's income for the year the amount, if any, by which (f) the total of all amounts each of which is the product obtained when (i) the designated cost to the taxpayer of the offshore investment fund property at the end of a month in the year is multiplied by (ii) 1/12 of the total of (A) the prescribed rate of interest for the period that includes that month, and (B) two per cent exceeds (g) the taxpayer's income for the year [(other than any income that would not be included in the taxpayer’s foreign accrual property income for the year if the value of C in the definition “foreign accrual property income” in subsection 95(1) were nil and other than a capital gain)] from the offshore investment fund property determined without reference to this subsection. ...