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10 May 2004 Internal T.I. 2003-005362-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Professional fees incurred by two corporations in connection with their merger and incurred after they decided to commit to the transaction would be eligible capital expenditures. ...

11 October 1994 Internal T.I. 9418166- EX GRATIA PAYMENT-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance An Ex gratia payment authorized by a Order in Council in connection with a wrongful dismissal grievance will be taxable either as employment income or a retiring allowance. ...

11 October 1994 Internal T.I. 9418166- EX GRATIA PAYMENT-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) An ex gratia payment authorized by an Order in Council in connection with a wrongful dismissal grievance will be taxable either as employment income or a retiring allowance. ...

2 March 1995 Internal T.I. 9433667- WITHHOLDING TAX ON OIL MARKETING FEES-- summary under Subparagraph 212(1)(d)(iii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(iii) Marketing fees would be exempt from Part XIII tax to the extent that they were paid for services performed by the non-resident in connection with the sale of crude oil or the negotiations of a contract for the resident. ...

20 November 2003 Internal T.I. 2003-0036237- DEDUCTIBILITY OF HST ASSESSMENT-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose GST penalties payable by the taxpayer would be deductible by it given that they were incurred in connection with a profit-making scheme and its conduct likely would not be considered to be "egregious or repulsive". ...

20 June 2007 Internal T.I. 2007-0233551I7- Deductibility of Transaction Costs-- summary under Paragraph 20(1)(cc) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(cc) auditor fees not deductible where no report Auditor fees incurred in connection with a proposed conversion of a corporation into an income fund which did not proceed were not deductible under s. 20(1)(cc) as no report was actually issued to a securities commission or other public body. ...

28 March 2006 Internal T.I. 2005-0109761I7 F- Commandite reçue par une athlète-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) sponsorship received by amateur student athlete was not from a source of income A sponsorship received by a student who was incurring significant expenses in connection with training and competitions involving her amateur sports activities were found not to relate to a source of income, and was not includible in her income. ...

5 June 1997 Internal T.I. 9704727- SPECIAL WARRANT ISSUE COSTS-- summary under Subsection 20(1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1) After referring, with respect to a question as to the deductibility of issue expenses incurred for special warrants, to the requirements in the preamble to s. 20(1), RC stated "that is, there must be a clear connection between the amount sought to be deducted and the issuance of the shares. ...

23 December 1993 Internal T.I. 9335957 F- Overseas Employment Tax Credit-Subcontractor (7070-7)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) Employees of a sub-contractor may qualify for the credit notwithstanding that the sub-contractor itself is not carrying on a qualified activity provided that the employees' duties are performed outside Canada in connection with a contract under which the sub-contractor carries on business outside Canada with respect to a qualified activity (i.e., of the main contractor). ...

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