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Automobiles in Opco's inventory were made available to each of Y, Mother and X's daughter ("DaughterX") for personal purposes, and a further automobile in Opco's inventory made available to X was used by X partly for personal purposes and partly in connection with X's employment with Opco. ...

5 November 2003 Internal T.I. 2003-0043277 F- Benefit-Use of Automobiles-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit conversion of automobile in car inventory to personal use of CEO would not entail its deemed disposition nor would the conversion of car inventory to personal use of shareholders Automobiles in the inventory of a car dealer (Opco) were made available to individuals related to the CEO (X), who was also an indirect controlling shareholder, namely to each of X’s brother (Y), Mother and daughter ("DaughterX") for personal purposes, and a further automobile in Opco's inventory made available to X was used by X partly for personal purposes and partly in connection with X's employment with Opco. ...

After noting that that former s. 34.2(3) likely permitted the taxpayer to continue claiming the reserve, and in connection with finding that the taxpayer had not been permitted to file an election under s. 249.1(4) to have a non-calendar fiscal period of March 31 in respect of the income from the business of the partnership he had joined, but that this did not matter because the election had already been made by the second partnership, the Directorate stated: Where a partner leaves a partnership to join another partnership, subsection 34.2(3) with respect to the meaning of "business" does not apply for the purposes of sections 34.1 (alternative method) and 249.1. … This means that where a partner joins an existing partnership, the fact that the partner previously carried on another business has no bearing on the determination of the fiscal period end of the business of the partnership being joined. ...

18 February 2022 Internal T.I. 2020-0836351I7- 212(1)(d)/Copyrights/Trademarks/XXXXXXXXXX-- summary under Paragraph 4(1)(b) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(b) allocation of expenses of a business carried on in two different countries 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. ...

After reviewing the history of Art. 10(8) (in particular, the expansion of the purpose test in 2003) and the OECD Commentaries, the Directorate concluded that “the intention of both Canada and the UK [was] that paragraph 8 of Article 10 of the Treaty not be limited to situations where the degree of connection of the ultimate dividend recipient with Canada is questioned,” i.e., it was not limited to situations of treaty-shopping. ...

In addition, since no acquisition of property occurs in connection with manufacturing salary and overhead costs, these amounts cannot be considered an amount paid by the taxpayer to acquire the particular property from a transferor of the particular property. ...

B’s prior agreement (in connection with the agreement with Mr. and Mrs. ...

In finding that such an adjustment was not permitted, the Directorate stated: [W]e find it difficult in this case to conclude that it would be reasonable to consider that the revision to the amount of capital cost allowance claimed by Opco for Year 1 relates to the misrepresentation made by Opco in connection with the calculation of its investment tax credit deducted pursuant to subsection 127(5) in computing its Part I tax for Year 1. ...

X apply a portion of his deemed forgiven amount under s. 80(15) to reduce the ACB of capital property to him, or a non-capital loss previously sustained by him, that had no connection to LP or its business and, in this regard, is s. 80(15)(c)(v) intended to limit the application of the X Debt forgiven amount only against tax items whose source of income is the same as the source in respect of which the underlying LP debt was issued? ...

. … The Distribution Agreement does not contemplate an extensive use of the trade-mark, but only limited use in connection with the distribution, promotion and advertising of the product granted under the gratuitous license to use the trade-mark for the commercialization of the Product in Canada. ...