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This working was subsequently considered in Wain-Town Gas & Oil [[1952] C.T.C. 147] (1952) 2 S.C.R. 377 where the taxpayer assigned to another company its franchise to supply a town with natural gas. ...

DEFINITIONS AND ABBREVIATIONS In this letter, unless otherwise expressly stated or the context otherwise requires: “Act” means the Canadian Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof, and unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; “Opco” means XXXXXXXXXX “Participant” means an employee of Opco who is a member of the Supplemental Plan (as defined below); “Plan” means Opco's group RRSP or Opco's RPP, as the case may be; “RCA” (or “retirement compensation arrangement “) has the meaning assigned by subsection 248(1); “RPP” (or “registered pension plan”) has the meaning assigned by subsection 248(1); “RRSP” (or “registered retirement savings plan”) has the meaning assigned by subsection 248(1); “SDA” (or “salary deferral arrangement”) has the meaning assigned by subsection 248(1); “Supplemental Plan” means the proposed Supplemental Pension Arrangement of Opco; RELEVANT FACTS 1. ...

La Convention prévoit que SPXY encaissera toutes les recettes, paiera toutes les dépenses d'opération et recevra une somme de 15 % des revenus d'opération à titre de frais de gestion. ...

The issue relates to how 127(5)(b) is to be interpreted POSITION: can't reduce minimum amount payable under Part 1 but can reduce surtax. 127(5)(b) is a relieving provision which enables an individual to carry back ITC which could otherwise be deducted but without any benefit to the individual because of minimum tax REASONS: when an individual pays minimum tax, Part 1 tax is calculated under Division E.1 so that there is no tax credits applied other than 127.531 & 127.54(2). ...

Paragraph # The client should be taxed on his contributions to an employee contributed 401(k) plan; a deduction under 110(1)(f) will be available on the rollover from the 401(k) plan to the IRA. ...

This working was subsequently considered in Wain-Town Gas & Oil (1952) 2 S.C.R. 377 where the taxpayer assigned to another company its franchise to supply a town with natural gas. ...

The eligible exploration expenses comprise Actual CEE incurred $ 97,000 Operator allowance $97,000 x 3%, say 3,000 $100,000 YOUR QUESTIONS You have asked: 1. ...

Ken & Ray's Collins Bay Supermarket Ltd., [[1975] C.T.C. 504] 75 DTC 5346 (FCTD). ...

28 June 1990 Income Tax Severed Letter ACC9596- Stock Bonus Plan Unedited CRA Tags 7 June 28, 1990 APPEALS BRANCH RULINGS DIRECTORATE Appeals & Referrals Division Financial Industries Division W.C. ...

This would have been particularly difficult in view of the fact that many of the otherXXX % of the shares were held by persons who were, by XXX representative's own admission, close associates of XXX while the remainder of the shares were widely-held by more than 200 shareholders. ...