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Assuming the connection conditions are met, would you apply s. 15(2.17)? ...

The CRA is closely monitoring developments at the OECD in connection with Pillar One, Amount A. ...

Question 14: Availability of Small Business Deduction Corporation A is a Canadian controlled private corporation that carries on active business in Canada, and holds property in connection therewith. ... Ronald Robertson and Roger Saunders, 2012 FCA 94.] have also stated that connections that are artificial should not be given weight in determining if income is situated on a reserve for purposes of the exemption. ...

What actions did the taxpayer take in connection with the reduction in value?” ...

This provision applies where there has been an increase in the total fair market value of the property held in connection with a registered plan that can reasonably be considered to be attributable, directly or indirectly, to a transaction or event (or series) if two conditions are met: the transaction or event would not have occurred in a normal commercial or investment context in which parties deal with each other at arm's length and act prudently, willingly and knowledgeably; and one of the main purposes of the transaction or event is to benefit from the plan’s taxexempt status. ...

A shareholder who receives property from a corporation in connection with the repurchase of the shareholder’s shares by the corporation disposes of those shares to the corporation in exchange for the property the shareholder receives. ...

This policy was assigned as security at the request of the lender (by way of a movable hypothec) in connection with a loan taken out to earn income from a business or property. a) Does the CRA agree with the conclusion set out in Interpretation Letter 19-045061-001 [FN18: REVENU QUÉBEC, Interpretation Letter 19-045061-001, "Calculation of Business Income- Deduction of Critical Illness Insurance Premiums- Assignment of Policy as Security- Commercial Loan", January 28, 2020.] rendered on January 28, 2020 by the Agence du revenu du Québec, which recognized that a taxpayer, in computing business or property income could deduct, as a guarantee expense, the premiums on a CII policy contracted and assigned to the lender at the latter's request, pursuant to s. 176.4 of the Taxation Act [FN19: RLRQ, c. ...

The T3 return serves to report information about the trust itself along with information that affects the taxation of persons who have some connection to the trust. ...