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Folio Summary
S4-F2-C1 - Deductibility of Fines and Penalties -- summary under A
S4-F2-C1- Deductibility of Fines and Penalties-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A 1.20 If a fine or penalty is incurred in connection with the acquisition of an asset for which capital cost allowance (CCA) may be claimed, the fine or penalty may be included in the capital cost of that asset (or the CCA class to which the asset belongs). ...
Folio Summary
S4-F2-C1 - Deductibility of Fines and Penalties -- summary under Cumulative Eligible Capital
S4-F2-C1- Deductibility of Fines and Penalties-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital 1.21 If a fine or penalty is incurred in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the subsection 14(5) definition of eligible capital expenditure are met. ...
Folio Summary
S4-F2-C1 - Deductibility of Fines and Penalties -- summary under Eligible Capital Expenditure
S4-F2-C1- Deductibility of Fines and Penalties-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure 1.21 If a fine or penalty is incurred in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the subsection 14(5) definition of eligible capital expenditure are met. ...
Folio Summary
S4-F2-C1 - Deductibility of Fines and Penalties -- summary under Subparagraph 40(1)(a)(i)
S4-F2-C1- Deductibility of Fines and Penalties-- summary under Subparagraph 40(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(i) 1.22 If a fine or penalty (such as a mortgage prepayment penalty) is incurred in connection with the disposition of a capital property, the fine or penalty is taken into account under subsection 40(1) for purposes of calculating any gain or loss on that disposition. ...
Public Transaction Summary
Loblaw/GWL/Choice -- summary under Butterfly spin-offs
Due Bill Trading Due Bill trading may only be used in connection with a “push-out” of listed securities (i.e. where the certificates representing the originally listed securities to which the entitlement attaches will not be replaced with new certificates; rather, only the entitlement (e.g. the dividend, shares of a new company, etc.) will be “pushed-out” to shareholders). In the case of the Arrangement, this means that Due Bill trading will only be used in connection with the LCL Common Shares, as the certificates representing the LCL Common Shares will not be replaced with new certificates. ...
Folio Summary
S2-F1-C2 - Retiring Allowances -- summary under Retiring Allowance
In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...
Folio Summary
S4-F8-C1 - Business Investment Losses -- summary under Subsection 39(9)
Therefore, in connection with the disposition of the debt, Mr. R’s 2015 tax return will also reflect an allowable capital loss in the amount of $60,000 ($120,000 x one-half). ...
Folio Summary
S4-F14-C1 - Artists and Writers -- summary under Commodities, and commodities futures and derivatives
An artist would generally be considered to have made a gift of capital property when the property gifted is property that would not normally be produced and sold in connection with their business. ...
Folio Summary
S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 56(1)(r)
S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 56(1)(r) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(r) The deduction [under s. 110(1)(g) by way of s. 56(1)(r)] applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student's training. ...
Folio Summary
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph 146(4)(a)
This position does not apply to borrowing that arises in connection with a cashless exercise of warrants or a margin account. ...