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20 January 1994 Internal T.I. 9400506 - CONSEQUENTIAL REASSESSMENTS

FACTS-A reassessment of XXXXXXXXXX 1986 taxation year by Scarborough District Office included the disallowance of certain capital losses claimed by XXXXXXXXXX with respect to shares which were subject to transactions which the D.O. considered to involve the circumvention of the superficial loss rules in paragraph 54(i). ...

22 March 1994 Internal T.I. 9402046 - CENTRE OF VITAL INTERESTS - XXXXXXXXXX EMPLOYEE (4093- U5-100-4)

On the other hand it is not clear as to how many of that 25% would have been considered dual residents to begin with. ...

6 May 1994 Internal T.I. 9321827 - WARRANTS RECEIVED BY NR AS PART OF POD (T2 FILE)

In particular, before the tax implications in transaction #4 can be determined (see comments below), it will be necessary to consider the application of section 212.1 of the Act with respect to transaction #3 and if such application would adjust the PUC of the preferred shares in XXXXXXXXXX With respect to transaction #4, since the warrants received are considered non-share consideration, the FMV of the warrants form part of the proceeds of disposition of the preferred shares in XXXXXXXXXX for capital gains purposes. ...

6 June 1994 Internal T.I. 9408117 - WAGE LOSS REPLACEMENT PLAN BENEFITS

On the other hand, to the extent that changes are considered to fall outside the exceptions, the resulting increase in benefits, as indicated in paragraph 21 of Interpretation Bulletin IT 428 "Wage Loss Replacement Plans", would be taxable while the remaining benefits would be exempt. ...

14 July 1994 Internal T.I. 9407377 - NON-RESIDENT PARTNER & 216 ELECTION (7558-3)

On the presumption that the non-resident partner is considered to be carrying on business through a permanent establishment in Canada, there would be no Part XIII tax liability in respect of the rent paid to the partnership by virtue of section 805 of the Income Tax Regulations. ...

10 August 1994 Internal T.I. 9419327 - EXPENSES INCURRED BY FISHERPERSONS

Factors to be considered in applying this test include the required investments to be made by the individual, permanency of the relationship, and the skill required by the individual. ...

1 September 1994 Internal T.I. 9413847 - DEDUCTIBILITY OF EXPENSES

We note that you have considered Interpretation Bulletins IT-359 and IT-467R and found no relief. ...

11 October 1994 Internal T.I. 9418166 - EX GRATIA PAYMENT

Szeszycki Programs Section (613) 957-8953 Nancy Kelly, Chief 941816 Taxation of Ex Gratia Payment This is in reply to your memorandum of July 14, 1994 in which you requested our assistance in determining whether an ex gratia payment received by XXXXXXXXXX, in connection with a wrongful dismissal settlement, is considered taxable. ...

30 September 1994 Internal T.I. 940767B - INT. OF 115(1)(B) & 116 WHERE A NON-RES. GRANTS AN OPTION

Finally, it should be noted that you also considered whether subsection 115(3) would apply in this particular situation and you concluded that it should not. ...

16 November 1994 Internal T.I. 9419477 - NON-CAPITAL LOSSES

They must therefore be considered in determining the amount under paragraph 3(c) of the Act in respect of the taxpayer. ...

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