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CRA then stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2003-03-28 18 March 2003 External T.I. 2002-0122845 F- CREDIT D'IMPOT POUR LE DOUBLAGE DE FILMS Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) timing of receipt of Quebec film dubbing credit 21 March 2003 External T.I. 2002-0161115 F- ALLOCATION DE FIN DE CARRIERE Income Tax Act- Section 146- Subsection 146(1)- Earned Income end-of-career allowance received by physician is not earned income 18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4) Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition 2003-03-21 19 March 2003 External T.I. 2002-0151015 F- ALLOCATION DU COUT EN CAPITAL Income Tax Regulations- Schedules- Schedule II- Class 16- Paragraph (e) the short-term use requirement in 16(e) must continue to be met following the acquisition Income Tax Act- Section 13- Subsection 13(5) Class 16 automobile must be moved to another class when it ceases to be used for short-term rentals 19 March 2003 External T.I. 2002-0171825 F- DEDUCTION POUR INSOLVABILITE LIQUIDATION Income Tax Act- Section 61.3- Subsection 61.3(1) winding-up in year does not preclude the s. 61.3 deduction 14 March 2003 External T.I. 2003-0001385 F- Capital Dividend Account Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a) no adjustments for change in capital gains inclusion rates Income Tax Act- Section 256- Subsection 256(9) amalgamation and acquisition of control on successive days created 1-day short taxation year ...

These are additions to our set of 2,552 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,558 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ½ years of releases of such items by the Directorate. ...

Fair market value is predominantly factual ….” It is suggested that fair market value (FMV) is not a “fact” in the sense provided by Phipson on Evidence, namely, “a statement that can be verified”, i.e., “can be proven to be true or false through objective evidence”, whereas evidence as to FMV is essentially opinion evidence. ...

CRA was then approached, who determined that GAAR applied to the rollout of the Holdings shares to Holdco, so that s. 104(5.8) should be treated as applying to the capital property of Trust 2 upon the (now imminent) occurrence of the 21 st anniversary of the formation of Trust 1 so as to result in a deemed disposition of such property pursuant to s. 104(4)(b)(ii) – and the Directorate so ruled in this ruling letter. ...

Summary of 2 November 2023 APFF Roundtable, Q.8 under s. 20(1)(a) – revising claims. ...

These are additions to our set of 2,642 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 21 ¼ years of releases of such items by the Directorate. ...

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...