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Conséquemment 1e remboursement pourra augmenter directement 1e revenu gagné ou réalisé par une inclusion dans le revenu selon l'alinéa 12(1)t) L.I.R. ou indirectement par une réduction des dépenses de A & D selon l'alinéa 37(l)e) L.I.R. ou de la déduction pour amortissement en raison que 1e coùt en capital d'un bien amortissable a été réduit en vertu du paragraphe 13(7.1) L.I.R. et de l'alinéa 13 (21) f) L.I.R. ...

In particular, Article IV(1)(a) defines the term “resident of a Contracting State” as follows: “For the purposes of this Agreement, the term “resident of a Contracting State” means: (a) any person who, under the laws of that State, is liable to tax therein by reason of that person’s domicile, residence, place of management or any other criterion of a similar nature, but does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein; and” [emphasis added] It has been our long-standing position, as stated in the Income Tax Technical News 35, Treaty Residence – Resident of Convenience, dated February 26, 2007 (“ITTN-35”), that, to be considered “liable to tax” for the purposes of the residence article of Canada’s income tax treaties, a person must be subject to the most comprehensive form of taxation as exists in the relevant contracting state. ...

The university issued a Form TL11A, Tuition and Enrollment Certificate – University Outside Canada (Form TL11A) and advised your son to use the letters of offer to report the scholarship and living allowance stipend amounts on his Canadian income tax and benefit return (Canadian Return). ...

It cannot exceed the amount determined by the formula A – B where: A is the income that the second CCPC has for its taxation year from the first CCPC referred to in paragraph 125(3.2)(a), and B is the portion of the amount described in A that is deductible by the first CCPC in respect of the amount of income of the first CCPC referred to in clauses 125(1)(a)(i)(A) or (B) for the year. ...

Reasons: See below. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 7. ...

Reasons: The liability pursuant to paragraph 94(3)(d) is not extinguished until the taxes owing by the trust in respect of that year are collected. 2023 STEP CRA Roundtable – June 20, 2023 Question 5. ...

| Revenue Québec (revenuquebec.ca) ...

For purposes of the Guidelines, “employer is resident on a reserve” means: “… that the reserve is the place where the central management and control over the employer organization is actually located. ...

Cette allocation est imposable à moins de faire partie des exceptions énumérées aux sous-alinéas 6(1)b)(i) à (ix) de la Loi de l'impôt sur le revenu (ci-après la «Loi »). ...

The Fund directly holds all of the outstanding units and notes of XXXXXXXXXX Trust, and indirectly holds limited partnership units of XXXXXXXXXX LP (representing approximately XXXXXXXXXX % of the outstanding limited partnership units of XXXXXXXXXX LP), all of the shares of GP Co (the sole trustee of the Trust, being the general partner of XXXXXXXXXX LP and Holdings LP), and all of the shares of Beneficiary, the sole beneficiary of the Trust. 3. ... However, advances evidenced by the Sub-Loan Note will bear interest at a rate of XXXXXXXXXX % per annum in excess of the interest rates under the New Credit Facility. 30. ...