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. … T5 slips will also have to be issued when interest is paid by the Brokers to their Clients. ...

. … As for FMV, it generally represents the highest price obtainable for a property on a sale in a free and open market between two willing, informed and prudent persons acting independently. ...

. … As for FMV, it generally represents the highest price obtainable for a property on a sale in a free and open market between two willing, informed and prudent persons acting independently. ...

The correspondent considered that the retained earnings of ULC should exclude its proportionate share of the Partnership income for the stub period on the basis that " 2007-0248961R3 indicate[s]... that section 96 informs the determination of the amount of partnership income to be included in determining the amount of a corporate partner's retained earnings for the purpose of the thin capitalization rules. ...

After finding that the individual’s income could not be excluded from income through a deduction under s. 110(1)(f)(iii) and was not exempt under s. 81(1)(a) (given the individual's continued Canadian residency), CRA went on to indicate that s. 126(3) could provide a credit, stating: We are of the view that XXXXXXXXXX constitutes an "international organization" within the meaning of subsection 2(1) of the [Foreign Missions and International Organizations Act] in that it includes XXXXXXXXXX states and governments …[and] no non-governmental organization is admitted as a member …. ...

. … Finally, before making any distributions from the estate, the executor is required to obtain a clearance certificate, pursuant to subsection 159(2)…. ...

…[T]he features described … in [the documentation], in and of themselves, would not cause the interest on the borrowed money to not be deductible.... ...

. … [T]he cost of land with standing timber characterized as a timber limit would be more appropriately included in Schedule VI rather than under Class 15 of Schedule IV…. ...

(at para 42)) rather than their cost – although, here, the denied operating expenses and CCA of the corporate owner "can be used to establish the value of the benefit conferred on Mr. ...

A's father, CRA indicated that there would be no taxable benefit respecting such use by the father for the years under review before the effective date of s. 15(1.4)(c) – but thereafter, the value of the benefit enjoyed by the father was taxable to the son (Mr. ...