Search - 阿里拍卖 司法拍卖

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) damages received for separated spouse’s unlawful use of taxpayer’s property were tax-free receipts Monsieur received damages from his separated common-law spouse (Madame) to compensate him for her use of his ½ co-ownership interest in a property as if she were the full owner. ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in ownership dispute were capital expenditures After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieurs obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

CCRA indicated that if this return of premium on death clause was ancillary to critical illness insurance, the insurance policy would be a sickness or accident insurance policy – in which case, there would be no taxable benefit under s. 6(1)(a) if it were a group sickness or accident insurance plan. ...

. … [T]he wording of the Act would not restrict the deductibility of contributions paid between 1989 and 2001, even though they were paid after the time that triggered the payment of the first benefits in 1988. ...

. … [Here] there was no replacement of the original obligation by another obligation between the Corporation and the debenture holders. ...

. … Consequently, this amount must be taken into account in determining Variable C in the formula in subsection 146.3(6.11). ...

In the case of a limited partnership … it is usually the general partner that can exercise these rights. ...

The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ...

The effect of C of the FAPI formula was that the OIFP rules generated FAPI to CFA, and Canco then picked up its share of such FAPI – and this combined operation of the FAPI and OIFP rules was not affected by dividends paid by FA to the CFA (inter-FA dividends are excluded form FAPI) nor was it affected by any dividends paid by CFA to Canco. ...