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Expense- Start-Up and Close-Down Expenditures no acceptance that expenses incurred before decision to proceed are thereby on current account Rio Tinto found that investment dealer fees incurred in connection with an acquisition but before the board determined to make the acquisition were fully deductible. ...

CRA indicated the quoted words did not establish a test that the beneficiary’s interest must be acquired as a result of the particular transfer being considered and that the definition instead seeks to ensure that there is no connection between the transfer, and the person or partnership that already has an interest in the non-resident trust, or would have such an interest in the future. ...

CRA indicated the quoted words did not establish a test that the beneficiary’s interest must be acquired as a result of the particular transfer, and the definition instead seeks to ensure that there is no connection between the transfer, and the person or partnership that already has (or will have) an interest in the non-resident trust. ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 7, 2021-0899681C6 F- Stock option, Short sale and Identical property-- summary under Subsection 39(4) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(4) s. 39(4) election can apply to both the dispositions occurring in connection with short sale transactions An employee, who engages in a short sale transaction to finance the exercise of stock options on the shares of the individual’s employer, short sells identical shares borrowed from a third-party lender and uses the short sale proceeds to inter alia fund the option exercise – and then uses the shares acquired on exercise to cover the short position. ...

Accordingly, if no other exclusions are met, s. 95(2)(b) would apply to services provided in connection with the sale of real estate inventory, including residential condominiums. ...

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. ...

2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Subsection 152(8) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(8) stay of proceedings under the BIA is a procedural limitation that does not affect an assessment’s validity The Girardi decision (2014 QCCA 1922) stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A. ...

In brief oral comments regarding Foix when a question about this case was repeated at the 2024 CTF Roundtable, CRA indicated that: the reasons in Foix should be carefully considered in connection with any proposed hybrid sale, with the one exception of transactions identical to those in Geransky; the decision reinforces the broad scope of s. 84(2), and the role of that subsection as an anti-avoidance provision; and that it represents a departure in some respects from the more restrictive view of s. 84(2) evident in some earlier cases. ...

Services provided in connection with difficulties at work could be an example of services principally for the benefit of the employer…. ...

A strong connection between the Gagliese Productions case and a mortgage-lending business is not apparent. ...