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In particular, Article IV(1)(a) defines the term “resident of a Contracting State” as follows: “For the purposes of this Agreement, the term “resident of a Contracting State” means: (a) any person who, under the laws of that State, is liable to tax therein by reason of that person’s domicile, residence, place of management or any other criterion of a similar nature, but does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein; and” [emphasis added] It has been our long-standing position, as stated in the Income Tax Technical News 35, Treaty Residence – Resident of Convenience, dated February 26, 2007 (“ITTN-35”), that, to be considered “liable to tax” for the purposes of the residence article of Canada’s income tax treaties, a person must be subject to the most comprehensive form of taxation as exists in the relevant contracting state. ...

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Cette allocation est imposable à moins de faire partie des exceptions énumérées aux sous-alinéas 6(1)b)(i) à (ix) de la Loi de l'impôt sur le revenu (ci-après la «Loi »). ...

The explanatory notes to paragraph 20(1)(e) state: Paragraph 20(1)(e) is amended to clarify that it does not allow a deduction for profit participation and similar payments — that is, payments dependent on the use of or production from property, or computed by reference to revenue, profits, cash flow, commodity prices or any other similar criterion or by reference to dividend payments. Where such payments are compensation for the use of borrowed money or for the right to pay a debt over time, they would be excluded by the existing paragraph 20(1)(e) — either because they are interest or because they fall within the broad definition of “principal amount” in subsection 248(1). ...

Civil Law Trust Richard Tremblay and Kim Wharram (footnote 11) summarize the most important characteristics of a civil law trust as follows: “… articles 1256 to 1298 of the new Civil Code of Quebec… now provide for a comprehensive trust regime that includes provisions for transfers of property to a trustee, and the administration of the trust property by the trustee… While this trust regime contains many concepts that are similar to common law principles relating to trusts, there are some notable distinctions. ... For Director International & Trusts Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 We do not know whether XXXXXXXXXX acted pursuant to the directions of XXXXXXXXXX. 2 However, at this time, XXXXXXXXXX was the Supervisor and per Article XXXXXXXXXX of the Articles of the Foundation, only XXXXXXXXXX could have appointed a new Supervisor. 3 We did not assess the Canadian income tax consequences of the change in Beneficiaries of the Foundation. 4 However, we question whether, pursuant to the laws of the Netherlands Antilles, a person can be the Founder (i.e. ...

.), the Federal Court-Trial Division considered the meaning of the term "... an amount has become payable to a taxpayer in a taxation year... ... In Mid-West Abrasive Company, the Court looked to the surrounding words and stated: "... 'In respect of the year' refers, in my opinion, to the year during which the borrowed money was used and not the year in which the lender chose to make the request for interest... ...

Le matériel auxiliaire comprend, entre autres, les meubles et les appareils, le matériel de réparation et d'entretien et les extincteurs d'incendie. (...) 11. ... Les biens qui sont utilisés pendant plus de la moitié du temps dans le cadre d'activités de fabrication ou de transformation peuvent faire partie de la catégorie 29, 39 ou 40, selon le cas. (...) 13. ...

In this respect, La Forest, J. stated that: "... one must guard against ascribing an overly broad purpose to ss. 87 and 89. ... " LaForest, J. concluded that: "... Indians, when engaging in the cut and thrust of business dealings in the commercial mainstream are under no illusions that they can expect to compete from a position of privilege with respect to their fellow Canadians. ...

As agreed with Brian Ellis (Ellis / Wong, July 30, 2002), we do not discuss in this reply the potential avoidance issues relating to these transactions undertaken in 2000, since these issues have been referred to Tax Avoidance. ... Based on an informal discussion with the Department of Finance (Hall / Wong, July 25, 2002), this interpretation is consistent with Finance's intention that subsection 17(1) apply retroactively to any year during which the amount in question was outstanding, provided that the amount ultimately remains outstanding for more than 12 months. 3 This intention is also evidenced in the following excerpt from the Technical Notes to the 1998 Amendments: "Subject to the exceptions in new subsections (7), (8) and (9), new subsection 17(1) will apply to all amounts owing by a non-resident person to a corporation resident in Canada where at any time an amount owing has been outstanding for more than a year, or an amount owing at any time ultimately remains outstanding for more than a year, and a reasonable amount of interest has not been included in computing the corporation's income in respect of the amount owing for the portion of the corporation's taxation year during which the amount owing was outstanding. ...

Paragraph (f) of the definition of CEE. 23) Metallurgical testing – Grinding or other physical tests performed on core sample and/or bulk sample Testing of the physical material of the deposit, on or off site. ... The CIM Definition Standards for Mineral Resources & Mineral Reserves (2014) are available at: https://mrmr.cim.org/en/standards/canadian-mineral-resource-and-mineral-reserve-definitions. ...