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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. ...

QUESTION Vous nous demandez si les montants de XXXXXXXXXX $ par mois reçus en vertu de l'article XXXXXXXXXX de la convention ci-dessus doivent être inclus dans le revenu de Madame en vertu de l'alinéa 56(1)b) de la Loi de l'impôt sur le revenu, ci-après la "Loi", pour les années XXXXXXXXXX à aujourd'hui. ... Il faut plutôt déterminer qu'est-ce qui est vraiment versé et non pas s'arrêter seulement aux termes de l'entente; en vertu de l'article XXXXXXXXXX de la convention, Madame reçoit un montant de XXXXXXXXXX $ en tant que prestation compensatoire pour sa part du patrimoine familial. ...

Glenn Leung HEADQUARTERS Reginal International Tax Auditor Income Tax Rulings Directorate International Advisory Service Section Vicky Liu International and Large Business Directorate 2024-101425 Compliance Program Branch Subject: Foreign Entity Classification of Arizona Limited Partnerships This is in response to your request for our views with respect to the classification of two Arizona Limited Partnerships – XXXXXXXXXX (“Partnership I”) and XXXXXXXXXX (“Partnership II”) for purposes of the Income Tax Act (the “Act”). ... Paragraph A of A.R.S. § 29-319 provides that a limited partner who participates in the control of the business may become liable for the obligations of the partnership. ...

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. ...

April 24, 2001 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division A. ... Instead of becoming repayable at the time his employment was terminated, XXXXXXXXXX the promissory note was amended so that repayment of the loan was not required until: " XXXXXXXXXX... " 10. The XXXXXXXXXX letter submitted by XXXXXXXXXX, indicates that, after all of the above transactions were completed, each of the individuals owned XXXXXXXXXX of the outstanding shares of the Company. ...

It is interesting to note the wording in paragraph (d) particularly ".... for removal or for collection for immediate removal... ... ") or Class 8 assets (machinery or equipment not included in Class 2). ... However, it is our view that the case at hand can be differentiated from the case of Will-Kare Paving & Contracting in that Class 2 (now Class 1) as a whole does not just relate to a specified industry, but it relates to production and distribution of electricity, heat, water and natural gas. 13. ...

Gledhill, This memo is in reply to your request for a technical interpretation dated November 26, 2020 regarding certain interactions between the operations of subsection 219(1) of the Income Tax Act (the “Act”) and paragraph 6 of Article X (“Article X(6)”) of the Canada – US Income Tax Convention (the “Treaty”). ... The concept of earnings closely parallels the accounting concept of retained earnings – relevant in the case of a corporation to the concept of distributable reserves – and for that concept, the income tax impact of losses is matched to the year which gave rise to the tax recovery. ... The cumulative earnings in Year 2 are $300 ($100 + $200), from which $100 are carved out since $100 in respect of Year 1 has been subject to branch tax in previous taxation years. ...