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Our Comments The fact that the special shares were issued for nominal consideration and have an aggregate redemption value of $ 199,665 does not mean that subsection 110.6(9) does not apply. ...

Position: Reduced accommodation charges- no, XXXXXXXXXX Payments- yes, PUA payments – yes. ...

The second amount (in clause (i)(B) of the description of Variable B) is determined by the formula C – D, where C is the executive remuneration of the eligible entity, or of the public parent corporation that controls the eligible entity, if any, for the 2021 calendar year (prorated based upon the number of days of the eligible entity’s, or the public parent corporation’s, fiscal periods in the calendar year, if those fiscal periods are not the calendar year), and D is the executive remuneration of the eligible entity, or of the public parent corporation that controls the eligible entity, if any, for the 2019 calendar year (prorated based upon the number of days of the eligible entity’s, or the public parent corporation’s, fiscal periods in the calendar year, if those fiscal periods are not the calendar year). ...

This working was subsequently considered in Wain-Town Gas & Oil [[1952] C.T.C. 147] (1952) 2 S.C.R. 377 where the taxpayer assigned to another company its franchise to supply a town with natural gas. ...

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. ...