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DEFINITIONS AND ABBREVIATIONS In this letter, unless otherwise expressly stated or the context otherwise requires: “Act” means the Canadian Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof, and unless otherwise stated, every reference herein to a Part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; “Opco” means XXXXXXXXXX “Participant” means an employee of Opco who is a member of the Supplemental Plan (as defined below); “Plan” means Opco's group RRSP or Opco's RPP, as the case may be; “RCA” (or “retirement compensation arrangement “) has the meaning assigned by subsection 248(1); “RPP” (or “registered pension plan”) has the meaning assigned by subsection 248(1); “RRSP” (or “registered retirement savings plan”) has the meaning assigned by subsection 248(1); “SDA” (or “salary deferral arrangement”) has the meaning assigned by subsection 248(1); “Supplemental Plan” means the proposed Supplemental Pension Arrangement of Opco; RELEVANT FACTS 1. ...

La Convention prévoit que SPXY encaissera toutes les recettes, paiera toutes les dépenses d'opération et recevra une somme de 15 % des revenus d'opération à titre de frais de gestion. ...

The issue relates to how 127(5)(b) is to be interpreted POSITION: can't reduce minimum amount payable under Part 1 but can reduce surtax. 127(5)(b) is a relieving provision which enables an individual to carry back ITC which could otherwise be deducted but without any benefit to the individual because of minimum tax REASONS: when an individual pays minimum tax, Part 1 tax is calculated under Division E.1 so that there is no tax credits applied other than 127.531 & 127.54(2). ...

Paragraph # The client should be taxed on his contributions to an employee contributed 401(k) plan; a deduction under 110(1)(f) will be available on the rollover from the 401(k) plan to the IRA. ...

This working was subsequently considered in Wain-Town Gas & Oil (1952) 2 S.C.R. 377 where the taxpayer assigned to another company its franchise to supply a town with natural gas. ...

The eligible exploration expenses comprise Actual CEE incurred $ 97,000 Operator allowance $97,000 x 3%, say 3,000 $100,000 YOUR QUESTIONS You have asked: 1. ...

Ken & Ray's Collins Bay Supermarket Ltd., [[1975] C.T.C. 504] 75 DTC 5346 (FCTD). ...

28 June 1990 Income Tax Severed Letter ACC9596- Stock Bonus Plan Unedited CRA Tags 7 June 28, 1990 APPEALS BRANCH RULINGS DIRECTORATE Appeals & Referrals Division Financial Industries Division W.C. ...

This would have been particularly difficult in view of the fact that many of the otherXXX % of the shares were held by persons who were, by XXX representative's own admission, close associates of XXX while the remainder of the shares were widely-held by more than 200 shareholders. ...

Our rationale for the above conclusion is based on the Wardean Drilling Limited case (1969 CTC 265) wherein Cattanach, J. stated at 271: "... it is my opinion that a purchaser has acquired assets... when title has passed, assuming that the assets exist at that tine, or when the purchaser has all the incidents of title, such as possession, use, risk, although legal title may remain in the vendor as security for the purchase price... ...