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Position Adoptée: Oui / Yes. Raisons: Libellé de la Loi / Wording of the Act. ... Contexte de la demande Votre demande est liée à un projet de cotisation émis à la société XXXXXXXXXX (« Contribuable ») le XXXXXXXXXX dans lequel le bureau des services fiscaux de XXXXXXXXXX (« BSF ») a déterminé que cette dernière doit rembourser un montant reçu de Subvention salariale d’urgence du Canada (« SSUC »). ... L’expression « rémunération de la haute direction » est définie au paragraphe 125.7(1). ...

Position Adoptée: Aucune / None. Raisons: Commentaires généraux / General comments. ... Le dictionnaire français Larousse, en version électronique, le définit comme signifiant « de façon unique, exclusive » ou « indique une restriction ». Le dictionnaire Oxford, en version électronique, donne le sens suivant au terme équivalent anglais « solely »: « only; not involving somebody/something else. ». ...

26 January 1996 Internal T.I. 9600487- NON-CAP LOSS WHERE T/P INCOME & LOSS FROM SIMILAR SOURCES Unedited CRA Tags 111(8) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Your question relates primarily to amount F in the formula E- F which is used to determine amount A in the formula (A + B)- (C + D + D.1 + D.2) which is used to calculate a non-capital loss under subsection 111(8) of the Act. ...

At the end of its taxation year ended March 31, 1996, an amount of $75,000 was included in computing the Corporation's income from its business for such year ((3/4 of proceeds of disposition of $200,000) minus (3/4 of eligible capital expenditures of $100,000)). 2) Our comments We are of the view that the CDA of the Corporation at the end of its taxation year ended March 31, 2000 would be computed as follows: Paragraph (c) of the definition of CDA in subsection 89(1) of the Act: Nil. = the total of all amounts each of which is an amount required to have been included under this paragraph as it read for its application to a taxation year that ended before February 28, 2000 = (1/3 x 3/4 of the proceeds of disposition of goodwill for the 1996 taxation year) minus (1/4 of the eligible capital expenditures made in the 1995 and 1997 taxation years) = (1/3 x 3/4 x $200,000)- (1/4 x $200,000) = $50,000- $50,000 = Nil Paragraph (c.1) of the definition of CDA in subsection 89(1) of the Act: $33,333. = 1/2 of the amounts required by paragraph 14(1)(b) to be included in computing the Corporation's income in respect of its business for the taxation year ended March 31, 2000. The amounts that were required by paragraph 14(1)(b) to be included in computing the Corporation's income in respect of its business for the taxation year ended March 31, 2000 would be determined as follows in the situation described above: = 8/9 x the "excess" = 8/9 x (variable E in the definition of cumulative eligible capital ("CEC") in subsection 14(5) minus (variable A in the definition of CEC + variable B in the definition of CEC) (= 8/9 x (3/4 of the proceeds of disposition of goodwill for the 1996 and 2000 taxation years) minus (3/4 of the eligible capital expenditures made in the 1995 and 1997 taxation years + the amounts previously included in the Corporation's income in the 1996 taxation year under paragraph 14(1)(b)) (= 8/9 x ((3/4 x $400,000)- ((3/4 x $200,000) + $75,000) (= 8/9 x ($300,000- ($150,000 + $75,000) (= 8/9 x $75,000 = $66,667 Consequently, the amount of CDA under paragraph (c.1) of the definition of CDA would be $33,333 (1/2 x $66,666). ... In that respect, you may contact the Director of the Technical Applications & Valuations Division of the Audit Directorate, Mr. ...

3 May 2010 Internal T.I. 2009-0338901I7- Adjusted Ontario SR & ED incentive balance Unedited CRA Tags TA 49(7) Principal Issues: Interpretation of TA 49(7). ... The amount of a corporation's adjusted Ontario SR&ED incentive balance is determined by the formula (M- N- P) / C. ... No ITCs expired in 2009 The variables of the formula would then be as follows: M = $110 Q = $110- $110 R = $50 N = nil (nil- $50) P = $40 The adjusted Ontario SR&ED incentive balance is equal to $70 ($110- $40). ...

19 November 1992 Internal T.I. 9233587 F- Indians-UIC & Glenn Williams Unedited CRA Tags 81, 153(1)(d.1), 153(1.1)   923358   L. Holloway   (613) 957-2104 November 19, 1992 District Office and Taxation Centre SupportBusiness and General DivisionSource Deductions Division      P. ... Cousineau Unemployment Insurance Benefits & Status Indians This is in reply to your facsimiled request for our comments on source deductions requirements for unemployment insurance benefits received by status Indians.  ...

21 May 1992 Internal T.I. 9210827 F- Pre-Production Expenses & 24(1) Unedited CRA Tags 18(1)(a), 9   921082   Glen Thornley   (613) 957-2101 May 21, 1992 S. ...

22 September 1992 Internal T.I. 9223397 F- Transfer Of Disability Tax Credit & Personal Tax Credit Unedited CRA Tags 118.3, 118(1)(b), 118(1)(d)   922339   A. Humenuk   (613) 957-2134 September 22, 1992 SYDNEY DISTRICT OFFICEPersonal and General SectionEnquiries and Office Examination Attention: K. ...

27 June 1989 Internal T.I. 57919 F- Corporation Qualifying as "Non-profit Corporation" for SR & ED Unedited CRA Tags 37(1)(a)(ii)(E), 149(1)(j), 149(8), 149(9) 19(1) File No. 57919   C.R. ... The major provisions encompassed in paragraph 149(1)(j) of the Act are as follows: (i)     no part of the non-profit corporation's income can be payable to, or otherwise available for the personal benefit of, any proprietor, member or shareholder; (ii)      the corporation cannot acquire control of any other corporation; (iii)      the corporation cannot carry on any business; (iv)     the corporation must expend amounts in Canada either on SR & ED directly undertaken by or on behalf of itself, or by payments to an organization described in clause 37(1)(a)(ii)(A) or (B) of the Act, and such expenditures cannot be less than 90%  of its income for the period; and (v)     the corporation must be constituted exclusively for the purpose of carrying on or promoting SR & ED. ... (c)     a description of the corporation's arrangements for obtaining funding. ...

12 December 1996 Internal T.I. 9629217- NON-CAPITAL LOSS & DIVISION C DEDUCTIONS Unedited CRA Tags 111(8) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Calculation of Taxable Income Business Loss $(10,000) Taxable Capital Gain 9,000 Net Income deemed to be nil under paragraph 3(f) 0 Capital Gains Deduction (9,000) Taxable Income 0 Non-Capital Loss Calculation as defined in subsection 111(8) Amounts B, C, D, D.1, D.2 0 Thus, Non-capital loss = A E is calculated as Business Loss + Amount deducted under 110.6 or 10,000 + 9,000 = $19,000 Less: F (9,000) Non-Capital Loss $10,000 It is clear from the technical notes to the 1985 amendments to subsection 111(8) of the Act that the intent of the amendments is to permit an individual to "preserve" a non-capital loss when the taxpayer has any of the deductions set out in part "E" of the formula for a non-capital loss which would reduce taxable income if the taxpayer had sufficient income. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...