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Pour se qualifier comme FEC en vertu de l’alinéa f), une dépense minière doit respecter le test d’objet de l’alinéa f): la dépense doit avoir été engagée « en vue de déterminer l’existence, la localisation, l’étendue ou la qualité d’une ressource minérale au Canada ». ... Alinéa f) de la définition de FEC. 23) Essais métallurgiques – Broyage ou autres essais physiques sur des carottes ou des échantillons en vrac Essais sur la matière du gisement, sur le site ou non. ...

"19 The bulletin lists the factors that the Inland Revenue considers when characterizing a foreign entity as either "transparent" or "opaque" for UK tax purposes.20 With a few exceptions, these factors are essentially based on the characteristics that make UK partnerships transparent as proposed by the Court of Appeal in Memec PLC.21 The | Inland Revenue confirms that in considering these factors, it looks at the foreign commercial law under which the entity is formed and the internal constitution of the entity. ... Brett Evers Technical Applications And Valuations Division ENDNOTES 1 Marc Darmo, International Tax Planning, Characterization of Foreign Business associations, 2005 Canadian Tax Journal, Issue # 2 2 Werner Heyvaert and Grégory Noyen, Belgian Ruling Committee Accepts Tax Transparency of Foreign Partnerships, Taxanalysts, April 27, 2006. ...

Sincerely, for Director International & Trusts 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 We note that an EIC is not fiscally transparent for Barbados tax purposes. ...

Subsection 80(2) of the Act provides, inter alia, as follows: Application of debt forgiveness rules — For the purposes of this section, (a) an obligation issued by a debtor is settled at any time where the obligation is settled or extinguished at that time (otherwise than by way of a bequest or inheritance or as consideration for the issue of a share described in paragraph (b) of the definition "excluded security" in subsection (1)); (b) an amount of interest payable by a debtor in respect of an obligation issued by the debtor shall be deemed to be an obligation issued by the debtor that (i) has a principal amount, and (ii) was issued by the debtor for an amount, equal to the portion of the amount of such interest that was deductible or would, but for subsection 18(2) or (3.1) or section 21, have been deductible in computing the debtor's income for a taxation year; (c) subsections (3) to (5) and (7) to (13) apply in numerical order to the forgiven amount in respect of a commercial obligation; At the 2010 Canada Revenue Agency (“CRA”) Roundtable, the CRA stated that the time at which an obligation is settled within the meaning of paragraph 80(2)(a) is a mixed question of fact and law and cannot be determined without an examination of all the circumstances of a given situation. ... Subsection 143.4(4) provides as follows: (4) Subsequent years — Subject to subsection (6), if at any time in a taxation year that is after a taxation year in which an expenditure of the taxpayer occurred, the taxpayer, or another taxpayer not dealing at arm's length with the taxpayer, has a right to reduce an amount in respect of the expenditure (in this subsection and subsection (5) referred to as the "prior expenditure") that would, if the taxpayer or the other taxpayer had had the right to reduce in a particular taxation year that ended before the time, have resulted in subsection (2) applying in the particular taxation year to reduce or eliminate the amount of the prior expenditure, the taxpayer's subsequent contingent amount in respect of the prior expenditure, as determined under subsection (5), is deemed, to the extent subsection (2) and this subsection have not previously applied in respect of the expenditure, (a) to be an amount received by the taxpayer at the time in the course of earning income from a business or property from a person described in subparagraph 12(1)(x)(i); and (b) to be an amount referred to in subparagraph 12(1)(x)(iv). ...

Condo # 2 was never constructed because the company went bankrupt. All or most of the parking lots that would have been available for condo # 2 were now totally vacant. ...

Le 21 mars 2005 Agence du revenu du Canada Direction des décisions Direction de la RS & DE en impôt 50, rue O'Connor S. ... CANCO aurait donc droit, à compter de cette date, à tous les avantages découlant d'un tel statut, dont le droit aux crédits d'impôt à l'investissement remboursables au taux de 35 % en vertu du paragraphe 127(10.1) et de l'article 127.1, dans la mesure bien entendu où elle se qualifie à titre de SPCC tout au long de l'année donnée. ...

LEGISLATION Subsection 18(9.1) Penalties, bonuses and rate-reduction payments — Subject to subsection 142.4(10), where at any time a payment, other than a payment that (a) can reasonably be considered to have been made in respect of the extension of the term of a debt obligation or in respect of the substitution or conversion of a debt obligation to another debt obligation or share, or (b) is contingent or dependent on the use of or production from property or is computed by reference to revenue, profit, cash flow, commodity price or any other similar criterion or by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation, is made to a person or partnership by a taxpayer in the course of carrying on a business or earning income from property in respect of borrowed money or on an amount payable for property acquired by the taxpayer (in this subsection referred to as a "debt obligation") (c) as consideration for a reduction in the rate of interest payable by the taxpayer on the debt obligation, or (d) as a penalty or bonus payable by the taxpayer because of the repayment by the taxpayer of all or part of the principal amount of the debt obligation before its maturity, the payment shall, to the extent that it can reasonably be considered to relate to, and does not exceed the value at that time of, an amount that, but for the reduction described in paragraph (c) or the repayment described in paragraph (d), would have been paid or payable by the taxpayer as interest on the debt obligation for a taxation year of the taxpayer ending after that time, be deemed, (e) for the purposes of this Act, to have been paid by the taxpayer and received by the person or partnership at that time as interest on the debt obligation, and (f) for the purpose of computing the taxpayer's income in respect of the business or property for the year, to have been paid or payable by the taxpayer in that year as interest pursuant to a legal obligation to pay interest, (i) in the case of a reduction described in paragraph (c), on the debt obligation, and (ii) in the case of a repayment described in paragraph (d), (A) where the repayment was in respect of all or part of the principal amount of the debt obligation that was borrowed money, except to the extent that the borrowed money was used by the taxpayer to acquire property, on borrowed money used in the year for the purpose for which the borrowed money that was repaid was used, and (B) where the repayment was in respect of all or part of the principal amount of the debt obligation that was either borrowed money used to acquire property or an amount payable for property acquired by the taxpayer, on the debt obligation to the extent that the property or property substituted therefor is used by the taxpayer in the year for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business. ... Thus, in each of XXXXXXXXXX and XXXXXXXXXX, the Taxpayer would only be permitted to deduct an amount of $XXXXXXXXXX in respect of the Redemption Premium (i.e., $ XXXXXXXXXX), rather than the amounts deducted by the Taxpayer of $XXXXXXXXXX and $XXXXXXXXXX, in XXXXXXXXXX and XXXXXXXXXX, respectively. ...

In compensation for the rights granted under the Distribution Agreement, Canco paid to NRco, as a non-refundable down-payment, the net amount of XXXXXXXXXX (the “Upfront Payment”) – XXXXXXXXXX paid upon signing of the Distribution Agreement and XXXXXXXXXX paid upon receipt of all governmental approvals by Canco required to distribute the Product in Canada. ... The Queen, 98 D.T.C. 2129 (T.C.C.), it was stated that a royalty payment is made “… for the use of property, rights or information whereby the payments for such use are contingent upon the extent or duration of use, profits or sales by the user.” ...

In this example the portion of the U.S. tax otherwise payable (before foreign tax credit) attributable to U.S. source dividend income is: = $100 x $92 = $41.82 $220 Then we need to compare this amount to the tax that the U.S. would be allowed to collect on such item of income if the taxpayer were not a U.S. citizen. ...

Principal Issues: Can RPP receipt be taxed where a deduction was not claimed on contribution Position: Yes Reasons: TPs argument that 4(4) will prevent the taxation of the amount is not accepted May 24, 1996 Toronto Centre TSO Headquarters Verification & Enforcement Division (613) 957-8953 Section 444-12, 438/7 Attention: Naomi Tsuji 7-960582 XXXXXXXXXX This is in reply to your memorandum of February 1, 1996, wherein you requested our comments on the submission by XXXXXXXXXX with respect to the deduction from income of excess contributions to a registered pension plan (the "RPP") and the inclusion in income of amounts on their withdrawal from the RPP. ... Abbreviated, the subsection reads: "... no provision... shall be read... to require the inclusion or to permit the deduction... from a particular source... of any amount... ...