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Facts The facts of the situation as we understand them can be summarized as follows: XXX The Department's Position Generally, an automobile allowance paid to an employee will be excluded from income if: (i) the allowance is not in excess of a reasonable amount (subparagraph 6(1)(b)(vii.1) of the Act) or in the case of an employee employed in connection with selling property or negotiating contracts for his employer, is a reasonable amount (subparagraph 6(1)(b)(v) of the Act); (ii) the allowance is based solely on the number of kilometres the vehicle is used to earn employment income (subparagraph 6(1)(b)(x) of the Act) and (iii) the employee is not reimbursed for any expense for the same use (kilometres) for which the employee is paid a travel allowance (subparagraph 6(1)(b)(xi) of the Act). ...

(ii) The contract in connection with which an employee performs duties in a foreign country must be one under which the specified employer carried on business in the foreign country. ...

Accordingly, the independent dealer in receipt of the benefit would include the amount of the benefit (i.e. equal to the rent amount paid by the operating company) in his income. 5) Because of concerns in connection with U.S. estate tax, the Canadian individual would incorporate a new Canadian company (Newco) wholly owned by him, to acquire the recreational property. ...

(b) Whether the guarantee fees arising from or in connection with the loan obligation acquire the same characteristics as interest payments on the loan obligation. ...

Concerning XXX, is our view that this represents an allowance for the use of the vehicle which is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the employee's office or employment and as such is required to be included. in the employee's income. ...

In this connection, we note that "active business carried on by a corporation" means any business carried on by the corporation other than a specified investment business or a personal services business. ...

(Emphasis added) It is quite probable that a shareholder may not in some jurisdictions be entitled to the financial statements filed in connection with an income tax return. (3) While there is an argument that the accounts are also ordinarily made up as of June 30 for income tax purposes, they may also ordinarily be made up monthly, quarterly, for some other reason(s) (internal use for budgeting, quarterly interest payment to creditors, use by government agencies other than the tax authorities etc.). ...

Il se peut que vous entendiez un signal sonore et qu’il y ait un retard avant la connexion de l’appel. ...

It also states that a payment made after December 20, 1991 that is otherwise a periodic pension payment would not be a periodic payment and thus subject to the full 25% Part XIII tax where, subject to certain exceptions, the total of all payments made under the RRIF at or before that time of the payment and in the year exceeds the greater of (a) twice the amount that would be the minimum amount under the fund for the year, and (b) 10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of a fund as consideration under the fund had been transferred immediately before the beginning of the year and the definition of “minimum amount” in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIF's. ...

It also states that a payment made after December 20, 1991 that is otherwise a periodic payment would not be a periodic payment and thus subject to the full 25% Part XIII tax where, subject to certain exceptions, the total of all payments made under the RRIF at or before that time of the payment and in the year exceeds the greater of (a) twice the amount that would be the minimum amount under the fund for the year, and (b) 10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of a fund as consideration under the fund had been transferred before the beginning of the year and the definition of “minimum amount” in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIFs. ...