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TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF- CONGRES 1992 Question # 54 SUJET: MONTANT NÉGATIF Revenu Canada, Impôt peut-il indiquer sa politique administrative concernant l'application de l'article 257 de la Loi aux différents articles de la Loi qui ne contiennent pas de "formules algébriques" tout en contenant, par ailleurs, une méthode de calcul. ...

"... may reasonably be considered to have been made in respect of the extension of the terms of or substitution or conversion of a debt obligation... ...

You referred to the situation where farmers enter into surface lease agreements with oil & gas companies and receive a lump sum payment in the first year for land damage. ...

Manitoba Bar Association & Institute of Chartered Accountants Question 4- Safe Income The issued and outstanding shares of Canco, a taxable Canadian corporation, are held as to 50% each by two corporations, A Co. and B Co., both of which are resident in Canada. ...

Noel A.C.J. makes the following comments: "..... the object of the contract, ie, the construction of the Belgian pavilion, was the execution of a type of work in line with the business for which it was created and which it normally and usually performs in its every day operations. ...

" and is specifically defined in subsection 146(1.1) of the Act for certain RRSP provisions and the pension registration rules in section 147.1 of the Act. ...

4 September 1992 Income Tax Severed Letter 2M01788 F- Taxe sur les produits et services (TPS) Unedited CRA Tags 60, 253 ADM'S OFFICE (3) ADM # 920527 RETURN TO RULINGS, ROOM 303, MET. ...

SUBJECT: BUTTERFLY EXEMPTION SECTION: 55(3)(b)] PRAIRIE PROVINCES TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 4 Application of Paragraph 55(3)(b) "Butterfly Exemption" Subco 2 is a wholly-owned subsidiary of Subco 1 which, in turn, is wholly-owned by Parentco. ...

The words used in subsection 246(1) specify that where at any time a person confers a benefit "... the amount of the benefit shall, to the extent that... and would be included in his income if the amount of the benefit were a payment made directly by the person to the taxpayer and if the taxpayer were resident in Canada... ...

Saint John Shipbuilding & Dry Dock Co. Ltd. [[1980] C.T.C. 352] (1989) D.T.C. 6372 (F.C.A.) ...