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In determining whether the inclusion of the dividend in the income of Canadian Resident under subsection 90(1) could be offset by another deduction or otherwise excluded from income on the basis that the income earned by S Corporation and supporting the payment of the dividend was previously included in Canadian Resident’ income as FAPI, subsection 248(28) should be considered: Unless a contrary intention is evident, no provision of this Act shall be read or construed (a) to require the inclusion or permit the deduction, either directly or indirectly, in computing a taxpayer's income, taxable income or taxable income earned in Canada, for a taxation year or in computing a taxpayer's income or loss for a taxation year from a particular source or from sources in a particular place, of any amount to the extent that the amount has already been directly or indirectly included or deducted, as the case may be, in computing such income, taxable income, taxable income earned in Canada or loss, for the year or any preceding taxation year; In this context, subsection 248(28) would not apply if the amount of the dividend paid by S Corporation that was included in computing Canadian Resident’s income under subsection 90(1) is not the same as the amount of FAPI that was directly or indirectly included in computing Canadian Resident’s income for a preceding taxation year under subsection 91(1). ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue.  ...

Where property is transferred to a corporation in exchange for shares with a par value, the transferor is considered to have realized proceeds equal to the fair,market value of the shares end not their par value. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...

In the case of a common-law partnership, the taxpayer would not be considered to have a common-law partner in applying the first-time homebuyer condition. 2) In the case of either a marriage or common-law partnership, subsection 146.01(2.1) provides relief from the first-time homebuyer condition. ...

In particular, subparagraphs 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that      "... can reasonably be considered to have been received (iii)     as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv)     as a reimbursement, contribution, allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of property or in respect of an outlay or expense". ...

To the best of your knowledge and that of the taxpayers involved: (i) none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and (ii) none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

Where property is transferred to a corporation in exchange for shares with a par value, the transferor is considered to have realized proceeds equal to the fair,market value of the shares end not their par value. ...

This is also true for the trustee/beneficiary who, in this particular situation, is not considered to have control over the decision to add a new beneficiary. ...