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. … [T]he NRCan Guide indicates that expenses for eligible property incorporated into a ground source heat pump system that qualifies for Class 43.2 treatment (by virtue of subparagraph (d)(i) of Class 43.1), include: The purchase and installation of heat pumps, pumps complete with controls and regulators. ...

2 November 2009 External T.I. 2009-0317541E5 F- Transfer to Corporations Owned by Brothers-- summary under Subparagraph 20(1)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) interest on debt assumed by Holdco to acquire non-dividend-bearing prefs of Opco was non-deductible even though commons also acquired – but amalgamation cured After a portion of the restaurant business of corporation (Corporation A) was spun off to a second corporation (Newco) in reliance on the s. 55(3)(a) exception and with the use of special voting-control shares in favour of the patriarch (A), with the two children of A (X and Y) then using interest-bearing loans to purchase most of the shares (being, in part, preferred shares) of Corporation A or Newco. ...

After stating that although “a director is generally considered to hold office, this is not the case for a director who works for a company solely on a voluntary basis,” which references the situation where “individuals who work on a volunteer basis receive no remuneration or at most minimal remuneration for services rendered on a volunteer basis” – with remuneration considered minimal where the remuneration paid to the individual is “significantly less than that which would have been paid to an employee or self-employed person rendering similar services,” so that “it is unlikely that minimal remuneration is sufficient to secure the volunteer's services.” ...

4 February 2009 External T.I. 2008-0292771E5 F- Régime de congé à traitement différé-- summary under Paragraph 6801(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 6801- Paragraph 6801(a) plan failed to provide: withdrawal must be in employer’s discretion; maximum deferral period of 6 years; a deferral period must precede leave; return to work required In the course of providing a detailed discussion (similar to that in 2016-0643191E5 F) of the DSLP rules in relation to a copy of a plan that had been submitted to it, the Directorate made various comments on perceived deficiencies in the terms, including that: the “plan should … be amended to provide that early withdrawal from the plan may only take place in specific circumstances set out in the plan and subject to the employer's discretion” the plan should be amended to clarity that the “deferral period does not exceed six years and all amounts held under the DSLP are paid to the employee by the end of the first taxation year commencing after the deferral period” the “plan provides that an executive on leave without pay, disability or parental leave may participate in the plan, but the leave cannot begin until the date of return to work. ...

If the Childcos were otherwise deemed by s. 256(2) to be associated with each other, but Parentco made three elections under s. 256(2)(b)(ii) not to be associated with each Childco, would the Childcos be associated corporations for s. 125 purposes – and, if so, would the taxable capital of Parentco and the other Childcos be taken into account in calculating the reduction in the business limit of a particular Childco under s. 125(5.1)? ...

In the scenario you presented, the non-resident corporate partner may, when calculating its Allowance … “look through” Partnership A to take into consideration Partnership B’s properties. ...

In the situations described above … a direct link should be made between the borrowed money and the funds received on the return of capital or contribution. ...

. … [A]ssuming that all the property transmitted to the various trusts comes from the testator, Mr. ...

If the request for a refund from the Romanian tax authorities is denied and the assessment is upheld, Xco may follow the procedures outlined in Article 25 [re MAP] … and make a written request to the CRA's Legislative Policy Directorate for a foreign tax credit. ...

Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...