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. … For example, section 409A permits payments to be made as a result of a reduction in service to less than 20% of the previous level, a change in control of the employer or an unforeseeable emergency. ...

A could under subsection 20(12) opt to claim, in his 2014 Canadian income tax return, an amount of up to $400…[which] would reduce the amount of his “non-business income tax” for 2014 …. ...

CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...

. … We are not aware of any provisions of the Act permitting the division or allocation of tax withholding between a trust and its beneficiaries. ...

In this type of arrangement (or one where the employee only receives advances during the leave – in which case, it is not within the DSLP rules), the employee is entitled to a s. 8(1)(n) deduction as the advances are “repaid” (i.e., out of reduced pay cheques following the return to work). ...

. … [Respecting] the last condition…provided that at the time FA Finco receives the amount of penalty, FA Holdco continues to hold the shares of FA Opco that constitute a source of income for FA Holdco, the fourth condition of Clause D would be satisfied. ...

. … …[T]his type of deduction would not be covered by any of the exceptions set out in the definition of "annuities" in Article 18, paragraph 5….. ...

XXIX(5) of the Canada-France Convention: [or as non-business income tax for the purposes of section 126]: CSG ("contribution sociale généralisée" ["general social contribution"]) CRDS ("contribution pour le remboursement de la dette sociale " [contribution for the repayment of the social debt]) Sécurité sociale vieillesse [old age social security] (retirement) Pole emploi (similar, in your opinion, to Employment Insurance) Retraite complémentaire [supplementary pension] (according to you, mandatory)? ...

2016 Ruling 2015-0612931R3- Variation of trust indenture-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition creation of new MFT units to indirectly bear trailer fees Proposed creation of new class of units to fund trailer fees The Declaration of Trust of an open-ended non-SIFT mutual fund trust (the “Trust”) with a corporate trustee (the “Trustee”) and with only one class of units will be amended to create two classes of units, so that the existing units will be re-designated as Class F units and a new class of units (Class A units) will be created which will have the same attributes as the Class F units except that they will bear exclusively an additional management fee, payable by an indirect subsidiary real estate operating LP to its GP (“Operating GP” – controlled by Trustee), which will fund the cost of trailer fees payable to investment dealers who have sold Class A units, with this resulting in a reduction of the distributions paid on the Class A, but not on the Class F, units. ...

The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...