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Taking into consideration the purpose of paragraph 1 of Article XVIII of the Convention and its interaction with section 691(c) IRC, you requested that we reconsider our interpretation of paragraph 1 of Article XVIII where an IRA or USPP amount is inherited by a Canadian individual with a view to allowing a deduction for related U.S. ...

L'expectative raisonnable de profit n'est rien de plus qu'un facteur parmi d'autres qui doit être pris en considération à ce stade. ...

Il est possible que cette somme comprenne un montant pour une période de préavis raisonnable ou que le salaire soit pris en considération pour déterminer le montant du dommage subi par l'employé (note de fin 5). ...

Question 2 In regards to your question concerning the deductibility by an LLC of salary that is declared as payable to a member of the LLC but that was not paid at year-end, we would expect that normal Canadian tax rules should apply to determine the deductibility of such amounts, taking into consideration subsection 78(4). ...

L'expectative raisonnable de profit n'est rien de plus qu'un facteur parmi d'autres qui doit être pris en considération à ce stade. ...

A personal trust is defined in subsection 248(1) of the Income Tax Act (the "Act") as a trust (other than a trust that is, or was at any time after 1999, a unit trust) that is: (a) a testamentary trust, or (b) an inter vivos trust no beneficial interest in which was acquired for consideration payable directly or indirectly to i. the trust, or ii. any person or partnership that has made a contribution to the trust by way of transfer, assignment or other disposition of property. ...

Whether a factual adoption has occurred at a particular time is a question of fact and has to be determined based on a consideration of the particular circumstances. ...

A Inc. assumed a vendor take back mortgage from the purchaser as partial consideration for the sale. ...

However, the determination of these issues would require a consideration of all the relevant facts and circumstances including the conduct and intentions of the particular parties involved and the terms of any agreement (whether written or oral) that might have been entered into by such persons. ...

The analysis should be carried out for each year and the adjustments should take into consideration any changes in the shareholdings. d. ...