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Thus, the CEE incurred in 1987 and 1988 would be available to Subscribers under the old rules only in respect of Earned Shares issued upon exercises of Rights that took place during 1986, this being the time that the new agreement in writing would be considered to have been entered into. ...

The following commentary could be added to paragraph 35 in order to provide guidance to the reader in interpreting the at-risk rules: A limited partner's at-risk amount will not be reduced in respect of amounts received by the partnership under a revenue guarantee, unless the revenue guarantee may reasonably be considered to ensure that the limited partner will receive a return of a portion of his investment. ...

Thus, the CEE incurred in 1987 and 1998 would be available to Subscribers under the old rules only in respect of Earned Shares issued upon exercises of Rights that took place during 1986, this being the time that the new agreement in writing would be considered to have been entered into. ...

We are of the view that where individual transactions are posted to subsidiary ledger and not to the general ledger, such subsidiary ledger should generally fall within the ambit of subparagraph 5800(a)(iv) of the Regulations. (3) Accounts and vouchers necessary to verify the information contained in the general ledger or other book of final entry are generally "non-permanent" records and therefore are to be retained for six years from the end of the last taxation year to which the records and books relate pursuant to paragraph 230(4)(b) of the Act. (4) It is a question of fact whether a lease would be considered a special contract or agreement pursuant to subparagraph 5800(a)(v) of the Regulations. ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

(footnote 5) Given the similarities between Gabon SCS and Ivory Coast SCS and partnerships in Canada, these SCSs should be considered partnerships for Canadian tax purposes. ...

In the Income Tax Folio S5-F2-C1 “Foreign Tax Credit” (footnote 2), it is observed that, where a dividend is received on shares of a corporation, the source of the dividend income should be determined based on the tax residency of the corporation paying the dividend, unless the provisions of a tax treaty sources this payment otherwise: 1.59 [I]n determining a dividend-paying corporation's country of residence for purposes of a foreign tax credit, the possible impact of the following should be considered: the provisions in an income tax treaty (if any) between Canada and the particular foreign country in question, that can determine the corporation's residence for the purposes of the treaty; and subsection 250(5), which (in conjunction with such a treaty) may deem the corporation to be not resident in Canada. ...

“Profit” is not defined in the Act but has been considered by the courts. ...

Yours truly, Kimberley Wharram Manager, Resources Section for Division Director Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 The accelerated investment incentives were announced as part of the Minster of Finance’s 2018 Fall Economic Statement on November 21, 2018. 2 Government assistance and non-government assistance are defined terms in subsection 127(9) of the Act. 3 The specified energy property rules are in subsections 1100(24) to (29) of the Regulations. 4 The relevant “available for use” rules are in subsections 13(26) and 13(27) of the Act. 5 Subsection 127.45(4) deems a taxpayer not to acquire clean technology property before it is considered to have become available for use by the taxpayer, determined without reference to paragraphs 13(27)(c) and 13(28)(d). ...