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B & J Music Limited, [[1983] C.T.C. 50] 83 DTC 5074 (F.C.A.), (that was heard prior to Stubart) considered whether the taxpayer had to bring into account in computing its “cumulative deduction account”, as defined in former paragraph 125(6)(b) of the Act, income for taxation years in which it was not a CCPC. ... B) 35% ITC Rate In the Supplementary Information issued by the Department of Finance on November 8, 1984, page 10 thereof states that “... the draft legislation published in August proposed a test to determine whether a CCPC qualifies for the three measures directed at small business: the 35% rate of ITC... ...

Proposed paragraph 13(27)(a) of the Act refers to the time that equipment is "... first used for the purpose of earning income... ... The words utilized in that particular paragraph "... first used... for the purpose of earning income," in our opinion means that the equipment must first be used in the function for which it was intended that would contribute to earning income and not merely used for the purpose of bringing the piece of equipment on line. ...

Our Opinion (1) Personal Services Business One of the requirements for the application of paragraph 125(7)(d) of the Act is that the "... incorporated employee would reasonably be regarded as an officer or employee of the person... to whom or to which the services were provided but for the existence of the corporation... ... George Thompson & Company Limited (1927), 13 TC 83. The court found it to be a question of fact whether or not different operations constitute one business or two separate businesses. ...

Exceptions to the above are provided "... where the contract provides that the right is not exercisable until the death, bankruptcy or permanent disability of an individual designated therein... ... " "... one which will remain substantially the same during remainder of workers' compensation claimant's life... ...

Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information You also but forward the following argument in your letter " the only apparent difference between the permissive activities through which an NRO is entitled to earn its income, ((ii)(A)) and the principal business prohibition, ((iv)(B)) is that it is permissible for the NRO to derive income from the "ownership" of debt obligations, but the principal business cannot be "trading or dealing" in debt obligations. ... " Our Comments Your request for an opinion does not contain sufficient facts to enable us to give you a definitive response, however we wish to provide you with the following comments on the issue raised in your query. ...

Peter Dixon & Son Ltd. 25 T.C. 353 is referred to in support of its argument. ... Peter Dixon & Son Ltd. there is no presumption in law that a discount at which a loan is made is in the nature of interest. ...

(Swiss Bank Corporation et al v MNR, 71 DTC 5235, at p. 5241 (Exch), affirmed at 72 DTC 6470 (SCC)): [....] where several parties- whether natural persons or corporations or a combination of the two- act in concert, and in the same interest, to direct or dictate the conduct of another, in my opinion the "mind" that directs may be that of the combination as a whole acting in concert or that of any one of them in carrying out particular parts or functions of what the common object involves. [....] ...

Calculation of safe income on hand: Operating income $10,000,000 Taxable capital gain 150,000 $10,150,000 Tax thereon (net of $2,000,000 tax credit) (2,872,000) 7,278,000 Untaxed portion of capital gain 150,000 7,428,000 Net outlay for SRTC note not deducted in computing income: Cost 4,000,000 Proceeds (2,300,000) 1,700,000 Gain included above 300,000 2,000,000 Safe income on hand $ 5,428,000 Reconciliation Operating income $10,000,000 Cost of investment (4,000,000) Proceeds on sale of investment 2,300,000 Income taxes paid (2,872,000) Safe income on hand $5,428,000 The analysis provided by XXXX refers to a difference between safe income and safe income on hand. ... Taxable income $3,000 Tax thereon at 50% $1,500 Less ITC 1,500 Tax payable NIL RITC $(5 500) Safe income on hand would be calculated as follows: Taxable income 3,000 Tax payable NIL 3,000 Net outlay not deducted in computing income: Cost $100,000 Proceeds (93,000) $7,000 RITC $5,500 $1,500 Safe income on hand $1,500 Reconciliation Operating income (assuming no difference in calculation of income for tax and accounting) $3,000 Proceeds from sale of asset 93,000 RITC 5,500 $101,500 Cost of asset (100,000) Safe income on hand $ 1,500 The above comments represent our interpretation of the guidelines as they would apply to the examples provided. ...

Trollope & Colk et al, v. Atomic Power Constructions, Ltd. (1962) 3 All E.R. 1035, and it is open to them, when they do so, to provide for interest to be payable on the outstanding sum left due over the relevant period of time. ... Kauffman A/Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Attachments ...

Cas # l Faits 1. 2. 24(1).../2 000080 24(1)Votre interprétation Selon vous la série d'opérations ou d'événements consistait à émettre des actions privilégiées et à les racheter et elle n'a pas eu comme résultat une augmentation sensible de la participation des tiers dans Opco puisqu'au début de la série d'opérations, les tiers détenaient 24(1) des actions émises et après la série de transactions, les tiers détiennent toujours 24(1) des actions émises. ... Dans votre cas, # 1 décrit ci-dessus, il s'agit de déterminer si 24(1) Il ne nous apparait pas inconcevable que des opérations de ce genre puissent faire partie de la même série d'opérations ou d'événements. ...