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. … Situation 2 Similarly, the CRA considers that the balance owing under the hypothec loan assumed by Child in the circumstances constitutes "an amount payable a property acquired"…. ...

Thus … subsections 15(1), 212(2) and paragraph 214(3)(a) would be likely to subject the non-resident to Part XIII tax. ...

. … In the situation you described, if the NCPI is lower than the premiums payable, it does not seem reasonable to conclude that the total amount of the NCPI for the year would be deductible by virtue of paragraph 20(1)(e.2) in computing the income of the corporation. ...

28 April 2015 External T.I. 2015-0566011E5- Whether s. 16.1 applies to a transport truck-- summary under Subsection 16.1(1) Summary Under Tax Topics- Income Tax Act- Section 16.1- Subsection 16.1(1) identification of lease based on legal substance/no election for transport truck Before concluding that "since a transport truck would be considered exempt property, a lessee and a lessor would not be entitled to elect under section 16.1…[so that] the lessee would not be entitled to deduct CCA on this vehicle, " CRA stated: As noted in Income Tax Technical News ITTN No. 21, it is our view that the determination of whether a contract is a lease or a sale for income tax purposes is based on the legal relationships created by the terms of the particular agreement, rather than the underlying economic reality. ...

However, where after entering into the contract with Canco, USCoinstead subcontracts a portion of the work to a Canadian subsidiary of USCo or an arm's length Canadian company, USCo will not be considered to have a PE in Canada provided such Canadian company is paid an arm's length fee – and similarly, if a US professional firm subcontracts part of its consulting contract with Canco to an arm's length Canadian professional partnership. ...

. … Finally, any person who would be affiliated with a majority-interest beneficiary in a particular RDSP Trust in the absence of paragraph 251.1(1)(g), should generally be affiliated with such trust. ...

" See more detailed summary under s. 55(1) – distribution. ...

. … Element B of the formula is the amount actually included in the CRIC's income on account of the interest with respect to the PLOI. ...

. … Element B of the formula is the amount actually included in the CRIC's income on account of the interest with respect to the PLOI. ...

. … Periods of absence from the workplaces abroad, in order to be included in the qualifying period, will generally have to be related to the contract with respect to the activities that are qualifying or consequential to the latter and the contract must be of a duration of more than six consecutive months in order for the employer to be considered to have carried on a business outside Canada for the purpose of the application of the OETC. ...