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The liabilities of the particular corporation (determined on a consolidated basis where appropriate) will then be allocated to, and be deducted in the calculation of, the net fair market value of each type of property of the particular corporation, as follows: (i)     current liabilities will be allocated to cash or near cash property to the extent of the aggregate fair market value of all property of that type; (ii)     liabilities, other than current liabilities, that relate to a particular asset will be allocated to the particular asset and to the type of property of the particular asset to the extent of the fair market value of the particular asset and any such liabilities not so allocated will be considered to relate to the type of property of the particular asset but not to the particular asset for the purposes of the allocation described in subparagraph (iii) below; (iii)     liabilities, other than current liabilities, that relate to a type of property but not to a particular asset will be allocated to that type of property to the extent of the net fair market value, determined after the allocation described in subparagraph (ii) above, of that type of property; and (iv)     any liabilities not otherwise allocated in accordance with the rules described above will be allocated to all types of property in proportion to, and to the extent of, the net fair market value, determined after the allocations described in subparagraphs (i), (ii) and (iii) above, of each such type of property; Any accounts receivable, inventory and prepaid expenses initially classified as cash or near cash property of the particular corporation that relate to a business of the particular corporation and that will be collected, sold or consumed by a corporation in the ordinary course of its business may, in appropriate circumstances, be reclassified as business property of the particular corporation.  ...

Such amounts are not considered to be exempted by virtue of the Canada-U.S. ...

In the case of land with a building thereon this term may be considered to refer to each of the land and the building thereon separately and, for purposes of this subsection the capital gain on each of these properties should be calculated separately. 3.      ...

The inquiry asked if a particular binding offer to lease would be considered a written agreement and whether an amount paid is a “qualifying rent expense” (“QRE”), as defined in subsection 125.7(1) of the Act, under the following circumstances: Landlord and taxpayer (“TP”) deal at arm’s length. ...

The memorandum from your Division has also indicated that for an amount to be considered as a "death benefit" pursuant to the definition of this term in subsection 248(1) of the Act, it must be "in recognition of the employee's service in an office or employment".  ...

It thus seems obvious that Finance has considered this particular issue and decided to make non-deductible any contributions made after 1990 by an employer pursuant to a collective bargaining agreement except where they meet the grandfathering provision in subsection 8516(4), or are otherwise described in section 8516 of the proposed Regulations.  ...

It should be noted however, that the scholarship or bursary income need not be received from the 19(1) In our view however, the continuation of salary for the period of leave in the taxpayer's circumstances cannot be considered as scholarship or bursary income. ...

Foreign currency funds on deposit are not considered to be disposed of until they are converted into another currency or are used to purchase a negotiable instrument or some other asset, i.e. foreign funds on deposit may be moved from one form of deposit to another as long as such funds can continue to be viewed as "on deposit". Term deposits, guaranteed investment certificates and other similar deposits which are in fact not negotiable, are considered funds on deposit. ...

Principal Issues: Whether amounts paid to terminate a business arrangement are deductible as current expenses notwithstanding that the payments were considered capital receipts to the recipient. ... The portion that related to the cancellation of fees that would otherwise have been deductible was considered on income account, with the remainder being capitalized. ...

You requested our comments on whether the use of a company aircraft by a shareholder/employee is considered to be an employment benefit or a shareholder benefit. ... The benefit to a shareholder-employee is generally considered to be derived in his or her capacity as shareholder and is taxable as a shareholder's benefit under subsection 15(1) if: (a) the shareholder-employee controls the corporation or is one of a related group that controls the corporation or any affiliated corporation, and (b) there is extensive use of the aircraft for personal purposes by the shareholder-employee or, because of the latter's position, by relatives or friends of the shareholder-employee. ...