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Therefore, the amount of safe income that would be attributable to the Shares immediately following the election to include $100,000 in income is made in 1994 will be determined using the following formula: A- (B * A) C where: A is the safe income of Opco attributable to the Shares on February 22, 1994, B is the increase to the ACB of the Shares as a result of the February 22, 1994 election, and C is the amount of the capital gain inherent in the Shares on February 22, 1994 before making the election referred to in B Accordingly, in the situation where the capital gain attributable to the Shares on February 22, 1994 is $285,000 and the safe income attributable to the Shares on February 22, 1994 is $185,000, it is our view that the election to include $100,000 of the capital gain in income in 1994 would result in safe income of $120,087 being attributable to the Shares immediately following the election on February 22, 1994. ...

Les cotisations versées à une convention de retraite ainsi que les revenus de la fiducie de convention de retraite sont assujettis à un impôt remboursable de 50 %. ...

Position TAKEN: Criteria are outlined Reasons FOR POSITION TAKEN: CCM # 5-933217, 3-932628 and 5-920441 XXXXXXXXXX 5-942198 Attention: XXXXXXXXXX May 5, 1995 Dear Sirs: Re: XXXXXXXXXX Further to our telephone conversation (Desparois/XXXXXXXXXX) of May 1, 1995, we are providing information to outline the tax differences between an approved research institute under clause 37(1)(a)(ii)(B) of the Income Tax Act (the "Act") and a non-profit corporation for scientific research and experimental development under paragraph 149(1)(j) of the Act (a "149(1)(j) corporation"). ...

., $30,000 + $50,000). As regards Scenario B, if the taxpayer elected proceeds of disposition of $1 in respect of 50% of their partnership interest, the election would give rise to a capital gain of $1 (i.e., $1- 0). ...

Faits 1.1X est une société canadienne imposable détenue à 100 % par Y, une autre société canadienne imposable. 1.2Les deux sociétés exploitent une entreprise de construction et calculent leur revenu provenant de contrats de construction selon la méthode d'achèvement des travaux. 1.3On veut liquider X dans Y. 1.4X a exclu de son revenu les sommes équivalentes aux retenues sur contrat et à la facturation non approuvée. ...

Le texte reporté mentionne ce qui suit: «The division's opinion was that, (...) any share of the trust's taxable capital gains could be attributed to her or him, provided that the share may reasonably be considered to be her or his share.» ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

In order for the exemption from tax for employment income to apply to status Indian employees that do not work nor reside on a reserve, Guideline 4 of the " Indian Act Exemption for Employment Income Guidelines" would have to apply. ...

With a view to assisting the Indian community, the Department has developed " Indian Act Exemption for Employment Income Guidelines" (the "Guidelines"), that describe the employment situations covered by the Indian Act. ...

Item # 10(a) of form T2200 simply asks the employer whether the employee was required under a contract of employment to use a portion of his or her home. ...