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At the end of its taxation year ended March 31, 1996, an amount of $75,000 was included in computing the Corporation's income from its business for such year ((3/4 of proceeds of disposition of $200,000) minus (3/4 of eligible capital expenditures of $100,000)). 2) Our comments We are of the view that the CDA of the Corporation at the end of its taxation year ended March 31, 2000 would be computed as follows: Paragraph (c) of the definition of CDA in subsection 89(1) of the Act: Nil. = the total of all amounts each of which is an amount required to have been included under this paragraph as it read for its application to a taxation year that ended before February 28, 2000 = (1/3 x 3/4 of the proceeds of disposition of goodwill for the 1996 taxation year) minus (1/4 of the eligible capital expenditures made in the 1995 and 1997 taxation years) = (1/3 x 3/4 x $200,000)- (1/4 x $200,000) = $50,000- $50,000 = Nil Paragraph (c.1) of the definition of CDA in subsection 89(1) of the Act: $33,333. = 1/2 of the amounts required by paragraph 14(1)(b) to be included in computing the Corporation's income in respect of its business for the taxation year ended March 31, 2000. The amounts that were required by paragraph 14(1)(b) to be included in computing the Corporation's income in respect of its business for the taxation year ended March 31, 2000 would be determined as follows in the situation described above: = 8/9 x the "excess" = 8/9 x (variable E in the definition of cumulative eligible capital ("CEC") in subsection 14(5) minus (variable A in the definition of CEC + variable B in the definition of CEC) (= 8/9 x (3/4 of the proceeds of disposition of goodwill for the 1996 and 2000 taxation years) minus (3/4 of the eligible capital expenditures made in the 1995 and 1997 taxation years + the amounts previously included in the Corporation's income in the 1996 taxation year under paragraph 14(1)(b)) (= 8/9 x ((3/4 x $400,000)- ((3/4 x $200,000) + $75,000) (= 8/9 x ($300,000- ($150,000 + $75,000) (= 8/9 x $75,000 = $66,667 Consequently, the amount of CDA under paragraph (c.1) of the definition of CDA would be $33,333 (1/2 x $66,666). ... In that respect, you may contact the Director of the Technical Applications & Valuations Division of the Audit Directorate, Mr. ...

Taxpayer's CEC Prior to After After Election Election Rollover 14(5)(A) $15,000 $15,000 $15,000 less: 14(5)(E) $ N/A $ N/A $22,500 14(5)(F) 1,000 1,000 1,000 CEC Balance $14,000 $14,000 $(8,500) *(no change) (see below) * However, the taxable capital gain realized on the CGD election ($7500) is added to a special account called the "exempt gains balance" (see Variable D below in 14(1)(a)(v) computation). Subsection 14(1) Computations 14(1)(a)(iv) Amount = $1,000 (to be included in income) (eg. lesser of: excess ($8,500) & Variable F ($1,000)) 14(1)(a)(v) Amount = $0 (to be included in income) (eg. ... Subsection 14(1) Computations 14(1)(a)(iv) Amount = $0 (eg. lesser of: excess ($8,500) & Variable F ($0)) 14(1)(a)(v) Amount = $8,500 (to be included in income) (eg. ...

26 January 1996 Internal T.I. 9600487- NON-CAP LOSS WHERE T/P INCOME & LOSS FROM SIMILAR SOURCES Unedited CRA Tags 111(8) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Your question relates primarily to amount F in the formula E- F which is used to determine amount A in the formula (A + B)- (C + D + D.1 + D.2) which is used to calculate a non-capital loss under subsection 111(8) of the Act. ...

21 May 1992 Internal T.I. 9210827 F- Pre-Production Expenses & 24(1) Unedited CRA Tags 18(1)(a), 9   921082   Glen Thornley   (613) 957-2101 May 21, 1992 S. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit CRA Tags 94(3) 94(1)(c) 126(1) Principal Issues: For the purposes of the foreign tax credit, will the amount of U.S. taxes paid on the actual disposition of marketable securities by the deemed resident trust need to be pro-rated to reflect the portion of the taxable capital gain that is subject to tax in Canada under proposed 94(3)(b)? ... In the October 24, 2012 Notice of Ways and Means Motion, the proposed legislation changed the non-resident trust rules as follows: 7. (1) Section 94 of the Act is replaced by the following: 94(3) If at a specified time in a trust's particular taxation year (other than a trust that is, at that time, an exempt foreign trust) the trust is non-resident (determined without reference to this subsection) and, at that time, there is a resident contributor to the trust or a resident beneficiary under the trust, (a) The trust is deemed to be resident in Canada throughout the particular taxation year for the purposes of (i) Section 2, (ii) … (iii) … (iv) … (v) … (vi) … (vii) … (viii) Determining the liability of the trust for tax under Part I, and under Part XIII on amounts paid or credited (in this paragraph having the meaning assigned by Part XIII) to the trust, (ix)... (x) …(b) No deduction shall be made under subsection 20(11) by the trust in computing its income for the particular taxation year, and for the purposes of applying subsection 20(12) and section 126 to the trust for the particular taxation year (i) In determining the non-business income tax (in this paragraph as defined by subsection 126(7)) paid by the trust for the particular taxation year, paragraph (b) of the definition "non-business income tax" does not apply, and (ii) If, at that specified time, the trust is resident in a country other than Canada, (A) The trust's income for the particular taxation year is deemed to be from sources in that country and not to be from any other source, and (B) The business-income tax (in this paragraph as defined by subsection 126(7)), and the non-business-income tax, paid by the trust for the particular taxation year are deemed to have been paid by the trust to the government of that country and not to any other government; (c) … Under proposed subparagraph 94(3)(b)(ii), there is no limiting wording that is similar to the current wording in clause 94(1)(c)(ii)(B) of the Act which requires that the foreign tax paid "can reasonably be regarded as having been paid in respect of that income" in order to qualify for the foreign tax credit. ...

22 September 1992 Internal T.I. 9223397 F- Transfer Of Disability Tax Credit & Personal Tax Credit Unedited CRA Tags 118.3, 118(1)(b), 118(1)(d)   922339   A. Humenuk   (613) 957-2134 September 22, 1992 SYDNEY DISTRICT OFFICEPersonal and General SectionEnquiries and Office Examination Attention: K. ...

8 December 2003 Internal T.I. 2003-0042537 F- CIEE & SRAS Also released under document number 2003-00425370. ... Comme pour chaque projet l'autorisant, la société a demandé à l'Agence des douanes et du revenu du Canada (l' " ADRC ") une autorisation de réduction d'impôt en vertu de l'article 122.3 de la Loi de l'impôt sur le revenu (la " Loi ") pour ces employés, car tous les critères étaient respectés, notamment celui de la période de six mois consécutifs à l'étranger. ... Durant la réalisation de ce projet, le Syndrome respiratoire aigu sévère (le " SRAS ") sévissait au Canada. ...

3 May 2010 Internal T.I. 2009-0338901I7- Adjusted Ontario SR & ED incentive balance Unedited CRA Tags TA 49(7) Principal Issues: Interpretation of TA 49(7). ... The amount of a corporation's adjusted Ontario SR&ED incentive balance is determined by the formula (M- N- P) / C. ... No ITCs expired in 2009 The variables of the formula would then be as follows: M = $110 Q = $110- $110 R = $50 N = nil (nil- $50) P = $40 The adjusted Ontario SR&ED incentive balance is equal to $70 ($110- $40). ...

19 June 1990 Internal T.I. 74779 F- Non-capital Losses & RRSP Contributions Unedited CRA Tags 3(a), 3(c), 146(1) earned income, 146(5)   June 19, 1990 THUNDER BAY DISTRICT OFFICE HEAD OFFICE Appeals Division Resource Industries   Section   Frank S. ... Christy (613) 957-9768 19(1) File No. 7-4779 SUBJECT:  Renounced Resource Expenses creating Non-Capital Losses & RRSP Contributions Resource Expense Deduction This is in response to your memorandum dated February 26, 1990, concerning the above-mentioned topics. ...

14 October 1998 Internal T.I. 9809347 F- TPS & TVQ- RESPONSABILITÉ D'ADMINISTRATEUR Unedited CRA Tags 40(2)g)(ii) 18(1)a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Les trois administrateurs ont été contraints de payer, en vertu de l’article 24.0.1 de la Loi sur le ministère du revenu et du paragraphe 323(1) de la Loi sur la taxe d’accise, les taxes de vente du Québec (ci-après « TVQ ») et les taxes sur les produits et services (ci-après « TPS ») impayées par la société à la date de la faillite. ...