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CDE – Canadian development expense as defined in subsection 66.2(5). CEE – Canadian exploration expense as defined in subsection 66.1(6). ... FTS – flow-through share as defined in subsection 66(15). PBC – principal-business corporation as defined in subsection 66(15). ... Additional comments on PBC criteria 1.11 A corporation might be engaged in activities listed in ¶ 1.3 as well as other business operations. ...

Employee contributions to a health and welfare trust are discussed in ¶ 1.37 to 1.39. ... For example, a health and welfare trust may offer a premium (contribution) holiday, provide additional health and welfare benefits under plans described in ¶ 1.2, or choose a combination of both. ... Subject to ¶ 1.37 to 1.39, the tax consequences to an employee arising from benefits provided under a health and welfare trust are described below. ...

In partnership law, a declaration of this type does not prevail over the actual facts of a situation (see ¶ 1.10). 1.7 In Continental Bank, Backman and Spire Freezers, the Supreme Court of Canada used the provincial and territorial partnership statutes to identify three fundamental criteria for determining whether a partnership exists in the common law provinces. ... As noted in ¶ 1.20(b), parties to a joint venture must have a right of mutual control and management. ...

As a result, there will be no proceeds of disposition in respect of that taxpayer and therefore no income inclusion (refer to ¶ 1.9). 1.7 Where an amount is included in a taxpayer’s income pursuant to subsection 106(2), a deduction may be available under subsection 106(1) for the cost of the income interest, if any. This is discussed in ¶ 1.18- 1.21. Further, paragraph 106(2)(b) deems any taxable capital gain or allowable capital loss from the disposition of the income interest to be nil. ... (Refer to ¶ 1.8.) 1.14 When subsection 248(8) applies, the more restrictive requirements of the definition of release or surrender found in subsection 248(9) must be met. ...

Windfalls 1.2 Subject to the comments in ¶1.3 and ¶ 1.11 to 1.29, an amount received as a windfall is not subject to tax. ... (See also Guide T4130, Employers’ Guide – Taxable Benefits and Allowances.) ... Where the prize in a lottery scheme is an annuity, see ¶ 1.29. 1.18 A lottery has been defined as a scheme for distributing prizes by lot or chance among persons who have purchased a ticket or a right to the chance. ...