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" As stated in this excerpt, the profit and loss experience is a factor in assessing whether a reasonable expectation of profit is present. ...

The term "Indian", as used in the Guidelines, is defined on page 10 of the Guidelines to mean "an Indian as defined for purposes of the Indian Act ". ...

Brian Arnold's article "Canada Amends Income Tax Convention Interpretation Act " published in Tax Notes International, vol. 18, Number 6, February 8, 1999. ...

" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope. ...

Cette allocation est payée sous forme d'avance mensuelle représentant un montant de XXXXXXXXXX francs belges, soit environ XXXXXXXXXX $ canadiens. 4. ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Subsection 200(1) of the Regulations states that "Every person who makes a payment described in subsection 153(1) of the Act [...] shall make an information return in prescribed form in respect of such payment.... ...

Our Comments Assistance for Tuition/Training Costs As indicated in our memorandum of March 1, 1999, (file # 990470) paragraph 56(1)(n) of the Act requires the inclusion into income of certain scholarships, bursaries and fellowships, with a $500 exemption. ...

ITRD has generally accepted that share appreciation rights (“SAR”) plans of the type described in ATR-45 – “Share Appreciation Rights Plan” would not be SDAs (“ATR-45 SAR Plans”). ...

13 November 2020 Internal T.I. 2020-0864831I7- Equity award plan and recharge agreement Unedited CRA Tags 7(3)(b), 248(1) “salary deferral arrangement”, 20(1)(oo), 15(1), 212(2)(a), 214(3)(a), 246(1) * Principal Issues: 1. ...