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Reasons: Similar to exemption for pension & RRSPs, and similar to treatment for active business income. 972866 XXXXXXXXXX D. ...

Reasons: a) It is clearly stated in Article IV of the Convention that the determination of Residence under that Article is to apply for the purposes of the entire Convention. b) See response to Question # 40 of 1984 ITF Round Table XXXXXXXXXX 980053 David R. ...

Principal Issues: whether an employee is taxed on the benefit of employer assistance with travel to work when seconded to a work place 700 km away & normally allowed to work at home rather than relocate Position: in the particular facts presented, yes Reasons: travel to employer’s place of business on a weekly basis is still personal even though the employee’s home is also considered a normal place of work for that employee- the exception in 6(6) for special work site would have applied if the employer had paid for the employee’s accommodation at the special work site but in the case presented, they choose to permit the employee to telework from his home except for weekly meetings. ...

Reasons: (1) Rachat intimement lié … la vente. (2) Ministère ne peux se prononcer sans avoir tous les faits pertinents. ...

Principal Issues: whether the 114 sq m. of land in excess of 1/2 hectare precludes a p/r exemption in respect of any of the land Position: no Reasons: when the land is in excess of 1/2 hectare & can’t be established to be necessary for the use and enjoyment of the housing unit as a p/r, the gain on the exempt portion must be calculated separately from the portion that is taxable XXXXXXXXXX 980682 A. ...

Les règles prévues à l’article 146.01 de la Loi concernant le RAP permettent aux particuliers de retirer jusqu’à 20 000 $ de leur RÉER pour acheter ou construire une habitation admissible. ...

Pursuant to B in the definition of “annual gains limit” in subsection 110.6(1) of the Act, an individual’s “annual gains limit” is reduced by: “... the total of (a) the amount, if any, by which (i) the individual’s net capital losses for other taxation years deducted (emphasis added) under paragraph 111(1)(b) in computing the individual’s taxable income for the year exceeds (ii) the amount, if any,...for the year, and (b) all of the individual’s allowable business investment losses for the year; (emphasis added)”. ...

In our view, the amount that results from the application of the subtraction equation in paragraph (a) in the definition of “capital dividend account” cannot be less than zero, because paragraph (a) states that: “ the amount, if any, by which (i)......exceeds (ii).....” ...

Principal Issues: Will the words "investing of its funds in property (other than real property)" in subparagraph 132(6)(b)(i) cease to be met where a mutual fund: 1) makes secured loans of its securities (which may not be viewed as “qualified securities” in section 260 of the Act- i.e listed on prescribed stock exchanges) or enters into repurchase agreements, 2) makes short sales of securities, 3) writes naked call options, and 4) invests in all manner of derivatives (including swaps), whether to take a position or to hedge, and whether they constitute "permitted derivatives" under National Policy # 39 of the Canadian Securities Regulators. ...

Principal Issues: whether Langley, Abbotsford and Yale form part of metro area of Vancouver and whether Nisku is part of the metro area of Edmonton for purpose of transport employee deduction Position: Langley & Abbotsford are part of metro Vancouver Nisku is part of metro Edmonton Although Yale is not part of metro Vancouver, no deduction under 8(1)(g) for regular runs between Yale and Vancouver Reasons: finding of fact for whether metro includes a certain municipality-for regularly scheduled trips between Yale and Vancouver, which would normally involve a regular 8 hour day, the deduction under 8(1)(g), while not limited by 8(4) is only available if the employee must routinely pay for meals and lodging because of the distance travelled. ...