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Otherwise, if they are considered to be general damages for non-pecuniary damage, no portion of which could be designated as a specified portion of a qualifying amount. ...

Consequently, the Intangible Expenditures will not be considered "eligible capital property," which is defined under s. 54 to mean property a part of the proceeds of disposition of which would qualify as an ECA. ...

10 March 2015 External T.I. 2014-0552551E5 F- Vente du droit d'exploiter une sablière-- summary under Qualified Farm or Fishing Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property sale of rights to extract sand could be considered sale of qualified farm or fishing property A family farming partnership ("SENC"), which owns a "qualified farm or fishing property," sells the right to operate the sand pit to a municipality for a fixed sum. ...

. … Furthermore, where a future income tax asset becomes a tax receivable, this tax must be considered as an asset in determining whether a share is a QSBCS or if a corporation is a SBC. ...

In response to this follow-up question, CRA confirmed that "if the Canadian parent earns a profit, then it would be considered to provide the services of its seconded employees in the course of its own business," and clarified that a mark-up over direct salaries will not result in FAPI if there is no profit element, i.e., the mark-up covers other costs such as employment benefits – and that whether more than that level of markup would result in an offsetting deduction in computing the FAPI of FA "depends on the proper determination of the related profit to be attributed to the activities of the relevant personnel. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...

Although by virtue of s. 55(5)(e)(iii), this presumption may be considered to deem the brothers to be related to the estate with respect to that acquisition, the brothers would still be deemed not to be related to each other and, therefore, would continue to be unrelated to the dividend recipient, Corporation A, in determining whether or not the "triggering" events described above for the purposes of paragraph 55(3)(a) are engaged. ...

11 June 2013 STEP Roundtable, 2013-0480321C6- 2013 STEP Question 6 US LLCs- FAPI, FAT and FTCs-- summary under Paragraph 113(1)(c) Summary Under Tax Topics- Income Tax Act- Section 113- Subsection 113(1)- Paragraph 113(1)(c) Is the US tax paid by a Canadian-resident taxpayer on the income (which also is foreign accrual property income) of an LLC which is owned by it (and is a controlled foreign affiliate) considered to be foreign accrual tax in respect of the LLC? ...