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18 February 2022 Internal T.I. 2020-0836351I7- 212(1)(d)/Copyrights/Trademarks/XXXXXXXXXX-- summary under Subparagraph 212(1)(d)(x) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(x) allocation of royalty between Canadian and non-resident business ordinarily made based on the respective revenues generated Royalties were payable by Canco to a non-resident for the right to use copyright and trademarks in connection with the design, manufacturing and sale of products in countries in a particular region. ...

In addition, this paragraph recognizes that where an employee continues to incur expenses in order to maintain the employee’s principal place of residence without receiving rental income in return, a benefit is not provided if the employer makes available, or reimburses, the expenses incurred in connection with a temporary residence at the particular work site. ...

In addition, this subsection recognizes that where an employee continues to incur expenses in order to maintain the employee’s principal place of residence without receiving rental income in return, a benefit is not provided if the employer makes available, or reimburses, the expenses incurred in connection with a temporary residence at the particular work location. ...

., 2 weeks’ salary) was to be excluded from employment income A directive regarding moving expenses of Quebec government employees provided that such employees were to be paid a lump-sum allowance equivalent to 2 weeks' salary to compensate for expenses related to the move, such as carpets, disconnection and connection of electrical appliances, cleaning, etc. – but further provided that in special justifiable circumstances, reimbursement of the following allowances could be authorized: a) a compensatory allowance for the self-moving of furniture, equal to 50% of the estimate of a moving firm, b) a compensatory allowance for the self-sale of the residence, established at 3% of the sale price, and c) in the event that the employee waived the employee’s right to the reimbursement of moving expenses, a compensatory allowance for additional moving expenses equaling 50% of the following: certain related expenses, real estate agent fees equivalent to 6% of the residence’s municipal evaluation, notary fees of $850 and the amount of a moving company estimate. ...

5 November 2012 Internal T.I. 2012-0462151I7- Foreign Tax Credits-- summary under Paragraph 126(6)(c) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(6)- Paragraph 126(6)(c) Canco held portfolio investments in shares of U.S. companies in connection with funding its insurance liabilities. ...

5 November 2012 Internal T.I. 2012-0462151I7- Foreign Tax Credits-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Canco held portfolio investments in shares of U.S. companies in connection with funding its insurance liabilities. ...

This… is intended to accommodate certain overdrafts of very short duration that are quickly or naturally reversed or that are infrequent and inadvertent…[and] does not apply to borrowing… in connection with a cashless exercise of warrants.... ...

. … There is a logical connection between the income from ULC and the U.S. taxes paid by Taxpayer because if Taxpayer did not own such shares, no U.S. taxes would have been paid [citing Smidth]. ...

This forward transaction was subsequently closed out by the taxpayer in connection with its sale of the Corporation 2 shares and use of the proceeds to repay the loan and pay a cash Maturity Payment to the Purchaser based in part on the appreciation in the shares’ value. ...

The trust then used dividend income received by it to repay part of the loan and then, in connection with winding up the trust, distributed the remaining trust property to the resident beneficiary, purportedly as an exclusively capital distribution. ...