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Accordingly, we suggest that line 2 under Exemption Code “G” be reworded to read “... in respect of the production or reproduction of any literary, dramatic, musical or artistic work (except...”. 2. ...

For purposes of the Act the complete definition of a retiring allowance is: "... an amount (other than a superannuation or pension benefit, an amount received as a consequence of the death of an employee or a benefit described in subparagraph 6(1)(a)(iv)) received (a) upon or after retirement of a taxpayer from an office or employment in recognition of his long service, or (b) in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal by the taxpayer or, after his death, by a dependant or a relation of the taxpayer or by the legal representative of the taxpayer". ...

With regard to the QSBCS definition, unless a particular inter-company receivable is an asset described in subparagraph (c)(i) of that definition, a determination would have to be made as to whether it was a "... bond, debenture, bill, note, mortgage, hypothec or similar obligation... ...

It is our view that a one time fee related to a loan with a term greater than one year, such a as a loan structuring fee or loan structuring fee or loan placement fee, would generally not "... reasonably be considered to relate solely to the year... ...

Our position remains as stated in answer to question 18 of the Thirty- Seventh Canadian Tax Foundation Conference, 1985 Revenue Canada Round Table Questions & Answers (a copy is enclosed for your convenience). ...

Your second concern deals with the meaning of the phrase "... any indebtedness in respect of a lease... ...

Clark Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

The capital gains exemption allowable is determined under subsection 110.6(3) and is the least of (a) the portion of the taxpayer's lifetime exemption which has not been used = $66,667; (b) the cumulative gains limit, which in this case is $10,000 less the CNIL balance of $1,000 $9,000; and (c) the annual gains limit, which in this case is $10,000. ...

Sales proceeds $100 "Soft costs" $10 Other costs 60 Total costs 70 Gross Profit $ 30 In this example, if the soft costs were incurred in the current year and the sale proceeds were fully due in the year, the gross profit to be reported in the current year would be $30. ...

Paragraph 18(1)(a) of the Income Tax Act (the “Act”) sets out the following conditions to be met in determining the deductibility of an expenditure: • expense or outlay must (a) be made or incurred by the taxpayer for the purpose of gaining, producing or maintaining income, and (b) be expected to generate income related to the taxpayer's business or property. ...