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15 November 2012 External T.I. 2012-0461291E5 F- Frais judiciaires pour clarifier une servitude CRA Tags 40(1)(a)(i) Principales Questions: Des frais légaux engagés dans un litige concernant la servitude d'accès à un lac grevée sur un terrain peuvent-ils être pris en considération dans le calcul du gain en capital relatif au chalet situé sur ce terrain, à titre de dépense engagée ou effectuée en vue de réaliser une disposition? ...

Response to Question 2: Where the shareholder was subject to an income inclusion in the year in which improvements are made by his corporation on commercial real estate rented from the shareholder, a subsequent transfer of the real estate to a wholly-owned subsidiary for fair market value consideration would not result in an additional inclusion in his income under subsection 15(1). ...

Generally, a plan will be considered to be a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement. ...

In the situation under consideration, the facts are not the same or similar to Folster since the taxpayer does not reside on a reserve and the XXXXXXXXXX does not have the same historical connection to the reserve. ...

In consideration of the Insurer making the Structured Payments, the Plaintiff settles the Statement of Claim against the Defendant. ...

If the newly incorporated CCPC (the pipeline corporation) has simply acquired the shares of the original corporation from the estate for consideration of a promissory note and has never commenced to carry on a business prior to distributing its property to the estate, the distribution of property to the estate could not have occurred on the discontinuance or reorganization of its business. ...

5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F- Discretionary Dividend Shares CRA Tags 15(1) 245(2) 110.6(7) Principal Issues: Whether the issuance by an operating corporation of discretionary dividend shares of its capital stock to a holding corporation for nominal consideration, as part of an asset protection plan, would be subject to any anti-avoidance provisions of the Act or would be acceptable in terms of tax policy? ...

The income of both parties is taken into consideration in determining the amount that one individual is required to pay, but both parties are not legally obligated to pay a support amount. ...

In making this determination, several factors including the location of the individual's belongings, where the individual receives his or her mail, and where the individual's immediate family resides, are taken into consideration. ...

Your request pertains to the application of the principal residence exemption in these circumstances in order that consideration could be given to amending your clients XXXXXXXXXX tax returns. ...