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The aforesaid subsections may be paraphrased as follows in stating the requirement as to when a principal-business corporation has to incur the various expenses so that they qualify for "flow through" purposes: "... and, during the period commencing on the day the agreement was entered into and ending 24 months after the end of the month that included that day, the corporation has incurred (the specific expense), the corporation may..., renounce,..., by which those expenses incurred by it during that period... ...

Monsieur A obtiendra un prêt hypothécaire (garanti par l'immeuble mentionné au paragraphe 4 ci-dessus) de 50 000 $ à un taux d'intérêt de 13% et prêtera les fonds a Opco sans intérêt. ...

19 April 1990 Income Tax Severed Letter AC80358- Canadian Exploration Expense of a New Mine DATE April 19, 1990 TO Appeals & Referrals Division FROM Rulings Directorate Appeals Branch DE Resource Industries Section Mr. ...

Marsh & McLennan Limited,83 DTC 5180. Nous ne pouvons nous prononcer à l'égard de votre question puisque celle-ci est une question de fait. ...

Beith in our memo dated October 11, 1988 (copy attached) and have no reason to change our position as reflected in paragraph 7 of this revision. 1) Paragraph 3(d) We suggest that you add the phrase "or loss of employment as the case may be " after "retirement" and change the word "case" to "situation". 2) Paragraph 4 In the last sentence, dealing with accumulated vacation pay, there is an implied suggestion that such pay may not be ordinary remuneration uf someone other than the employee terminates the employment which is no the case. ...

Chief Services, Public Utilities & Exempt Corporation Section Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Le Bulletin d'interprétation IT-486R, daté du 31 décembre 1987, intitulé "Transferts entre générations d'actions d'une corporation exploitant une petite entreprise" mentionne ce qui suit aux paragraphes 5 et 6: Paragraphe 5: "... ...

An example, which you supplied, explains further: Net Income before tax, $1,500,000 Bonuses and interest on A's advances (260,000) Less: Bonus to 8 20% (1,500,000- 200,000) Interest to A on advances (120,000) (say 12% x ($1,500,000) Bonus to A- (80% x (1,5000,000- 200,000))-120,000 (920,000) Net Income before tax $ 200,000 You question whether the bonuses are deductible in the year of accrual and whether the amendments to section 12 of the Income Tax Act ("the Act") apply to interest paid on shareholder advances. ...

Payments made to facilitate the re-leasing of that space, whether to the same tenant or a new tenant, may be either deducted in the year in which the expense is incurred, or deferred and amortized to income over the term of the related lease. (* What law? ...

Otherwise, we would not consider that "... that business was carried on... ...