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. … [S]ubparagraph 149(5)(e)(ii) … is intended to only exclude taxable capital gains from property that is required and used exclusively to meet the objectives of the tax-exempt NPO. [T]he parcel of land was used as a golf range for a brief five-year period (1998–2002) of its 35-year ownership (1990 to 2024). … [S]uch limited or historical use is insufficient to meet the threshold of being property used exclusively for and directly in the course of providing facilities to members. ...

The result in the amended return for Holdco would be that there would be federal tax payable in respect of the application of subsection 55(2) of $193,333 ($1,000,000 * 50% * 38 2/3%, of which $153,333 could be recovered in the event of a possible dividend payment by Holdco of at least $399,999). ...

., $1,800 = $1,000 + $800). Neal Armstrong. Summary of 20 January 2021 Internal T.I. 2019-0832211I7 under s. 126(1). ...

CCRA noted that “it is the net loss or income determined under the Act that is … attributed” pursuant to s. 74.1(1), so that “the interest expense paid by Ms. A … will be taken into account in determining the loss or income to be attributed to her spouse … pursuant to subsection 74.1(1)” – but that s. 245(1) might be determined to apply. ...

After quoting from Nassau Walnut to the effect that where the Minister changes the provision under which the taxpayer’s income is computed and the taxpayer then seeks a deduction under the new provision, that request “ does not raise the spectre of retroactive tax planning,” the Directorate then stated that here: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

The New Trust will not file an election under s. 248(1) – disposition – para. (f) – subpara. (v) for that para. not to apply. Subsequent transactions Prior to the Winding-up Date, the Initial Trustee will exercise his discretionary power pursuant to the Deed of Trust for the New Trust for making an advance determination of the portions of the trust capital and income which will be distributed among Mr. ...

…Paragraph 96(1)(a)[‘s] … presumption that a partnership is a separate person … does not apply for the purposes of section 152.... Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... The debt of the partnership is owed by the partners …. ...

CRA stated that “the principal question is whether the payment is made as a consequence of the individual's death” and, in addition to referencing the s. 248(8)(b) rule, noted that “paragraph 248(8)(a) provides, in particular, that a transfer … of property made … as a consequence of [the taxpayer’s] will is considered to be a transfer … made as a consequence of the death of the taxpayer.” ...

Aco will be able to deduct the portion of the periodic amounts of the consideration relating to the use of the property …. By contrast, the portion of the periodic amounts of the consideration relating to the acquisition of a purchase option on the Vehicle should be considered as expenditures of a capital nature for the acquisition of a capital property. … To the extent that Aco exercises its purchase option … Aco's cost of the Vehicle pursuant to subsection 49(3) will be the sum … paid in accordance with the exercise price … plus the adjusted cost base of the option, which will be the portion of the consideration paid that is attributable to the acquisition of that option. ...

31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual” An individual received home care for 24 hours a day from an attendant for tasks such as getting up, washing, and preparing meals. ... In the course of a general discussion regarding whether the test of "one full-time attendant … for the full-time care of the individual" was satisfied, the Agency stated: [T]he expression "one full-time attendant" is not intended to mean one attendant only looking after the patient on a continuous basis but rather several attendants could be utilized over a specific period of time so long as there is only one attendant for any given period of time. … [T]he expression “one full-time attendant … for the full-time care of the individual” … does not impose a minimum period of time during which care must be provided by a particular attendant. ...