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However, if the beneficiary's capital interest is an interest in a "personal trust" (as defined in subsection 248(1) of the Act) and the interest was acquired by the beneficiary for no consideration, there is no such ACB reduction under paragraph 53(2)(h). ...

By virtue of that provision, the total consideration to the taxpayer for the government right (which will enter into the calculation of an EC amount) is reduced by the greater of the following two amounts: the taxpayer's pre-1972 cost of acquiring the government right (or of acquiring the taxpayer's original right in respect of the government right), to the extent that such cost has not previously been deducted in calculating the taxpayer's income; and the fair market value, as at December 31, 1971, of the taxpayer's specified right in respect of the government right. ...

Another consideration in determining whether a corporation is liable for any Part I.3 tax is the "capital deduction". ...

When an audit is being conducted, it is advisable for a charity to make all relevant documents available for consideration. ...

Another consideration in determining whether a corporation is liable for any Part I.3 tax is the "capital deduction". ...

Exempt health care services The general rule under the Excise Tax Act (the Act) is that every recipient of a taxable supply, other than a zero-rated supply, made in Canada shall pay tax calculated at the rate of 5%, 12%, 13%, or 15% (depending on the place of supply) on the value of the consideration for the supply. ...

Specified foreign property includes all of the following: funds or intangible property (patents, copyrights, etc.) situated, deposited or held outside Canada tangible property situated outside of Canada a share of the capital stock of a non-resident corporation held by the taxpayer or by an agent on behalf of the taxpayer an interest in a non-resident trust that was acquired for consideration, other than an interest in a non-resident trust that is a foreign affiliate shares of corporations resident in Canada held by you or for you outside Canada an interest in a partnership that holds a specified foreign property unless the partnership is required to file Form T1135 an interest in, or right with respect to, an entity that is a non-resident a property that is convertible into, exchangeable for, or confers a right to acquire a property that is specified foreign property a debt owed by a non-resident, including government and corporate bonds, debentures, mortgages, and notes receivable an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: property in your registered retirement savings plan (RRSP), pooled registered pension plan (PRPP), registered retirement income fund (RRIF), registered pension plan (RPP), or tax-free savings account (TFSA) foreign investments held in Canadian mutual funds property you used or held exclusively in the course of carrying on your active business your personal-use property For more information on specified foreign property, see Form T1135, Foreign Income Verification Statement. ...

Specified foreign property includes all of the following: funds or intangible or incorporeal property (patents, copyrights, etc.) situated, deposited, or held outside Canada tangible or corporeal property situated outside of Canada a share of the capital stock of a non-resident corporation held by the taxpayer or by an agent on behalf of the taxpayer an interest in a non-resident trust that was acquired for consideration, other than an interest in a non-resident trust that is a foreign affiliate shares of corporations that are residents of Canada held by you or for you outside Canada an interest in a partnership that holds a specified foreign property unless the partnership is required to file Form T1135 an interest in, or right with respect to, an entity that is a non-resident a property that is convertible into, exchangeable for, or confers a right to acquire a property that is specified foreign property a debt owed by a non-resident, including government and corporate bonds, debentures, mortgages, and notes receivable an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: property in your registered retirement savings plan (RRSP), pooled registered pension plan (PRPP), registered retirement income fund (RRIF), registered pension plan (RPP), or tax-free savings account (TFSA) foreign investments held in Canadian mutual funds property you used or held exclusively in the course of carrying on your active business your personal-use property Note You have to file Form T1135 for 2020 no later than April 30, 2021, (or June 15, 2021, if you or your cohabiting spouse or common-law partner carried on a business in 2020, other than a business whose expenditures are primarily made in the course of a tax shelter investment). ...

Another consideration in determining whether a corporation is liable for any Part I.3 tax is the "capital deduction". ...

For purposes of determining whether a corporation has carried on an active business as a member of a partnership, as referred to in the subsection 125(7) definitions of "specified partnership income" and "specified partnership loss" (see ¶ 21), the following rules should be taken into consideration: the subsection 125(7) definition of "active business carried on by a corporation" (see ¶ 3); the subsection 125(7) definition of "income of the corporation for the year from an active business" (see ¶s 4 to 6); the meaning, in subsection 129(4), of "income" or "loss" of a corporation for a taxation year from a source that is property (see ¶s 4 to 6); and the subsection 125(7) definition of "specified investment business" (see ¶s 11 to 15 and ¶ 17) and the exclusion of a business from that definition if there are more than five full-time employees throughout the year (as discussed in ¶s 11, 15 and 17). ...