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The application of a statute barred overpayment of tax to other liabilities payable to the Crown was considered in Landmark Auto Sales Ltd. v. ...

The fact that Father would hold shares representing XXXXXXXXXX votes and would control Opco would not, in and by itself, result in the Common shares being considered as not having full voting rights in the situation described above. ...

A similar situation to yours was considered in External Interpretation document 2006-0167861E5. ...

Subject to the exceptions set forth in subparagraphs 12(1)(x)(v) to (viii) of the ITA, paragraph 12(1)(x) of the ITA provides, among other things, that any amount (other than a prescribed amount) received by a taxpayer in the year must be included in income from a business or property, if it is received from a government and can reasonably be considered to have been received as assistance whether as a grant, subsidy, forgivable loan or deduction from tax, allowance or any other form of assistance in respect of an amount included in the cost of property. ...

Starting with the fact that the Shares are considered a liability under GAAP (or as Chief Justice Bowman described it, debt), the Shares fit within the meaning of subordinated indebtedness and are long-term debt of the Taxpayer. ...

We have considered the application of subsections 70(1) and (2) since these are the only provisions that could possibly result in the Settlement Amounts being included in a deceased person’s income. ...

Like the ETA, under most PST legislation, vehicles are generally considered tangible personal property, and when accepted as a trade-in, the legislation specifies that the PST is calculated on the difference between the value of the property sold and the credit allowed for the value of the trade-in. ...

As XXXXXXXXXX fails to qualify as a religious order, the specific employee in question cannot be considered to be a member of a religious order. ...

You have asked whether these transfers should be considered as part of the determination of relevant amounts for the purposes of Part I.3 of the Income Tax Act ("ITA"). ...

For information on the factors to be considered in determining if a gain from the sale of real property is on account of capital or income, the taxpayer may wish to refer to paragraph 3 of Interpretation Bulletin IT- 218R, Profit, Capital Gains and Losses from the Sale of Real Estate, Including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa. ...