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Tax Interpretations Translation
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1) -- translation
15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- translation ...
Decision summary
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Paragraph 12(1)(c)
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The son of the taxpayers (Mr and Mrs Pope), who was the beneficiary of a life insurance policy which he had purchased on his own life, was abducted in Angola by rebels in 1998. ... In 2002, the provider paid the £100,000 principal amount insured, plus an additional amount of £36,425.97. ... The payment had clearly been made as compensation for the deprivation between 1998 and 2002 of the principal amount. ...
Decision summary
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber) -- summary under Subsection 104(13)
Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. In 2002 the insurer paid the £100,000 principal amount insured to the taxpayer, plus an additional amount £36,425.97, which the Tribunal determined was interest. ...
8 June 2014- 11:28pm Francis & Associates – Tax Court of Canada finds that substantively-correct bad debt deductions cannot be claimed in an amended return Email this Content Due to problems with its accounting system, a law firm did not discover until late in 2005 that billings made in 2002 to 2004 and which had become bad in those years had not been written off in the accounts. ... Summary of Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 under s. 20(1)(p)(i). ...
10 October 2024 APFF Financial Strategies & Instruments Roundtable
Miscellaneous correspondence
Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A – B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A – B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A – B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A – B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...
TCC
Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476
Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476 Date: 20010823 Docket: 1999-1979-IT-G BETWEEN: TORONTO REFINERS & SMELTERS LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... GENERAL: [1] All statutory references herein are to the Income Tax Act (" Act ") unless otherwise stated. ... COURT FILE NO.: 1999-1979(IT)G STYLE OF CAUSE: Toronto Refiners & Smelters Limited v. ...
T Rev B decision
B B Fast & Sons Distributors LTD v. Minister of National Revenue, [1982] CTC 2002, 82 DTC 1017
B B Fast & Sons Distributors LTD v. Minister of National Revenue, [1982] CTC 2002, 82 DTC 1017 Guy Tremblay:—This case was heard in Winnipeg, Manitoba on February 13, 1981. ... The Point at Issue The point at issue is whether or not the appellant, B B Fast & Sons Distributors Ltd and Willmar Window Industries Ltd were associated corporations during the 1975, 1976 and 1977 taxation years. ... H A Fawcett & Son, Limited v HMQ, [1979] CTC 303; 79 DTC 5224; affirmed by [1980] CTC 293; 80 DTC 6195; 10. ...
Technical Interpretation - Internal
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1)
15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1) Unedited CRA Tags 85(1)(e.2) 85(7.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... La lettre du 20 juin 2002 exposant la cotisation projetée, que vous avez envoyée au représentant du contribuable. La lettre du 14 août 2002 du représentant du contribuable contenant ses représentations suite à la vôtre du 20 juin 2002. ...
Technical Interpretation - External
16 May 2002 External T.I. 2002-0135765 - E-Commerce & Computer Software
16 May 2002 External T.I. 2002-0135765- E-Commerce & Computer Software Unedited CRA Tags 212(1)(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Position Paper Internet Commerce, which evolved from 2 sources:- a 1998 CCRA Technical Advisory Group (TAG) on Interpretation & International Cooperation; and- The "Taxation Framework Conditions", agreed upon in Ottawa in 1998 by member countries of the OECD. 2. ... Gilles Gosselin May 15, 2002 ...
Technical Interpretation - External
5 September 2002 External T.I. 2002-0147315 - PARTNERSHIP AS A PARTNER & 98 (3)
5 September 2002 External T.I. 2002-0147315- PARTNERSHIP AS A PARTNER & 98 (3) Unedited CRA Tags 98(3) 102(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Gibbons, CGA September 5, 2002 Dear XXXXXXXXXX: We are replying to your email dated June 17, 2002, concerning whether subsection 98(3) of the Income Tax Act (the "Act") may be used when one of the partners in the particular partnership is itself a partnership or even if all of the partners are partnerships. ...