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X's capital cost ($200,000) and the amount by which that cost exceeded the proceeds of disposition ($50,000) would be deemed to be CCA deducted in preceding taxation years, whereas “the capital cost to the corporation of the building for the purposes of all other provisions of the Act would, in accordance with our position in paragraph 10(a) of … IT-217R … be considered to be Mr. ...

If no s. 107(2.11)(a) election is made, does a distribution of the appreciated property of the trust to the non-resident beneficiary necessarily result in the taxable capital gain realized on that distribution being considered to be payable to the non-resident beneficiary so that the trustee would be required to withhold Part XIII tax respecting such amount? ...

MNR, 81 DTC 449 (TCC), the judge stated that he considered the established practice of previous years, the accounting entries in the books and the reference in the financial statements of the taxation year to be sufficient evidence of a legal obligation in that case. ...

Regarding the life insurance policy, it stated that “[t]he age and health of the insured, the value of the accumulation fund, the cash surrender value and the amount of premiums paid at the date of transfer are all factors to be considered in determining the FMV.” ...

. … This situation is similar to that considered ….in... Irving Oil …. ...

On the other hand, the Agency is of the view that the legal form should continue to be considered with respect to items that are to be included in the capital calculation as loans, advances or debts. ...

The age and health of the insured, the value of the accumulation fund, the cash surrender value and the amount of premiums paid at the date of transfer are all factors to be considered when determining the fair market value of a life insurance policy. ...

The age and health of the insured, the value of the accumulation fund, the cash surrender value and the amount of premiums paid at the date of transfer are all factors to be considered when determining the fair market value of a life insurance policy. ...

10 October 2003 Roundtable, 2003-0037135 F- CONTRATS DE RENTE VIAGERE-- summary under Subsection 301(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 301- Subsection 301(1) annuity did not qualify as a "life annuity" where payments made to a corporation Where an annuity may be payable during the lifetime of an individual, who may be an employee or shareholder of a corporation, and the corporation is the purchaser and owner of the annuity contract and is also the beneficiary of the annuity payments, will the annuity contract be considered a life annuity contract within the meaning of Reg. 301? ...

If the weekly allowance … was to compensate the employee for actual expenses for "board and lodging" at the special work site, we are of the view that the amounts would be considered reasonable …. ...