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Other Issues Pertaining to Both Treaties Your Views In considering the application of both the U.K and Dutch Treaties with respect to the phrase "in connection with the offshore resources" a possible allocation problem must be taken into consideration. ...

We have given full consideration to the excerpts from XXX but we do not find it to be of any assistance in providing a technical interpretation of subparagraph 66.1(6)(a)(iii.1). 15. ...

Accordingly, we believe that an important consideration, inter alia, would be whether the old plan could be regarded as one under which an employer has made a contribution for the purposes of paragraph 6(1)(f) of the Act. ...

POSITION OF THE DEPARTMENT OF FINANCE 1) From a tax policy perspective, it is clear that each expenditure under consideration as an SR&ED expenditure must meet the required criteria (i.e., it must meet the tests in subparagraph 37 (7) (c) (ii)). ...

In so far, however, as the capital additions and improvements were received as consideration for agreeing to deliver 60 cycle power at a price that was lower than would otherwise have been economic, I should be inclined to think that it was probably received on revenue account in accordance with the ordinary principles of commercial trading. ...

In fact, the Federal Court of Appeal decision for Burnet (footnote 6) supports the view that an ascertainment is a “definite undertaking” by the Minister to take the loss in question “into consideration” for the taxation year and “issue a Notice of Determination accordingly.” ...

Succession a transféré XXXXXXXXXX actions de catégorie « A » du capital-actions de Société (ci-après les « Actions Transférées ») en faveur de Nouco, en considération de XXXXXXXXXX actions de catégorie « A » du capital-actions de Nouco, à savoir des actions avec droit de vote et participantes, et du Billet 1, du Billet 2, du Billet 3 et du Billet 4 (collectivement les « Billets ») ne portant pas intérêt, en paiement absolu et complet. ...

2022 Ruling 2022-0925601R3 F- Post-mortem Pipeline Unedited CRA Tags 84(2), 84.1, 245(2) Principal Issues: 1) Whether section 84.1 will apply to reduce the PUC on the shares of the new corporation received as consideration for the disposition of the shares. 2) Whether subsection 84(2) will apply to the proposed transactions. 3) Whether subsection 245(2) will apply to the proposed transactions. ...

This requires consideration of all the circumstances, including the terms and conditions that apply in respect of the award, the duration of the program and the period for which the support is intended to be provided. ...

Consideration should be given to whether or not the actions or contributions of the other individual vis-à-vis the PWD or the person with an infirmity (e.g., for the purpose of computing element D of the formula in subsection 118.2(1), or a tax credit under paragraph (d) of element B in the formula under subsection 118(1)) are of such a nature and degree that they could be said to constitute support of the particular individual, and that a relationship of factual dependency can be said to exist, that is, reliance on that support. ...