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Technical Interpretation - External

6 April 2000 External T.I. 2000-0009395 - SHARES OF CORPORATION QUALIFIED INVESTMENT

A qualifying business may, however, include a business of leasing property other than real property. ... For the purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

28 June 2000 External T.I. 2000-0031635 - RRSP Investment in Shares of CCPC

A qualifying business may, however, include a business of leasing property other than real property. ... For the purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

4 July 2000 External T.I. 2000-0034345 - SHARES AS QUALIFIED INVESTMENTS

A qualifying business may, however, include a business of leasing property other than real property. ... For the purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

22 February 2001 External T.I. 2001-0067715 - Qualified investment, CCPC shares

A qualifying business may, however, include a business of leasing property other than real property. ... For purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

5 August 1999 External T.I. 9912145 - RRSP INVESTMENT IN SHARES OF CCPC

A qualifying business may, however, include a business of leasing property other than real property. ... For the purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

21 October 1999 External T.I. 9918255 - CCPC SHARES HELD IN AN RRSP

A qualifying business may, however, include a business of leasing property other than real property. ... For the purposes of these requirements, an "active business" is, in general, defined as any business carried on by a taxpayer other than a "specified investment business" or a "personal services business". ... Gains from the disposition of real property may or may not be from an active business. ...
Technical Interpretation - External

8 October 1993 External T.I. 3M09520 - APFF 1993

Where a source of income acquired with borrowed money is disposed of in exchange for cash and other income-generating company, and the cash is used by the taxpayer for personal expenses, normally only a part of the interest will still be deductible corresponding to the proportion of the value of the income-generating property to the value of all the property received in exchange for the original source of income. ... XXXXXXXXXX Question 20 Foreign accrual property income Canco has two wholly-owned foreign affiliates, USCO and AFCO, whose only income is active business income from a business carried on in a country listed in Regulation 5907(11). ... Revenue Canada response 1)      In preparing a response we have assumed that Canco does not derive the value of its shares principally from real property situated in Canada for the purposes of Article XIII(3) of the Canada-United States Tax Convention (hereafter "the Convention") or from the alienation of personal property as indicated in Article XIII(2) of the Convention.       ...
Technical Interpretation - External

6 October 2010 External T.I. 2010-0381231E5 - Extensive Trading in Securities

Some of the factors to be considered in ascertaining whether a taxpayer's conduct indicates the carrying on of a business are listed in paragraph 11 of IT-479R and include, amongst other factors, the frequency of transactions, the period of ownership, and the taxpayer's knowledge and time spent studying the securities market. ... Active Business Income For the purposes of the small business deduction, the expression "active business carried on by a corporation" is defined in subsection 125(7), and means any business carried on by the corporation other than a specified investment business or a personal services business and includes an adventure in the nature of trade. If a taxpayer's course of conduct indicates that the taxpayer is carrying on a business in a similar manner as a trader or dealer in securities, then, in our view, the "principal purpose" of the business would not be to derive income from property (for instance, rental income or interest income) and the corporation would not be considered to be a "specified investment business. ...
Technical Interpretation - External

24 October 2002 External T.I. 2002-0155925 - DEDUCTIBILITY OF DAMAGES

It states that payments for damages may be deductible in computing income if they meet the following tests: (a) the outlay must have been made for the purpose of gaining or producing income from business or property (paragraph 18(1)(a) of the Income Tax Act (the "Act"); (b) the outlay must not be on account of capital (paragraph 18(1)(b) of the Act); (c) the outlay must not be made for the purpose of gaining or producing exempt income (paragraph 18(1)(c) of the Act); and (d) the outlay must be reasonable in the circumstances (section 67 of the Act). ... Subsection 15(1) of the Act provides that the amount or value of a benefit conferred on a shareholder by the corporation is required to be included in computing the shareholder's income, except to the extent that the benefit is conferred by any of the items listed in paragraphs (a) to (d) or to the extent that it is deemed by section 84 to be a dividend. ... Generally, where a corporation pays for a personal expense of a shareholder, a benefit has been conferred on the shareholder and the amount of the benefit is included in computing the shareholders income pursuant to subsection 15(1) of the Act. ...
Technical Interpretation - External

2 November 2000 External T.I. 2000-0049505 - RRIF TRANSFER TO DEPENDENT CHILD

As a general rule the last annuitant under a RRIF is considered to receive a benefit immediately before death equal to the fair market value of the property held in the RRIF at that time. ... Unless the contrary is established, it will be assumed that a child was not financially dependent upon the deceased for support at the time of death if the child's net income for income tax purposes in the year preceding the death of the deceased, was greater than the amount used in calculating the basic personal credit in subsection 118(1) of the Act (set at $7,044 for deaths occurring in 2000). ... Local telephone numbers for these agencies are listed in the blue pages of your phone book. ...

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