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Provided such expense cannot be considered to be reserves for accounting purposes we would agree with your conclusion that such differences should not be adjusted for in the calculation of capital pursuant to proposed subsection 181.2(3). ...

Our comments As in the first situation outlined above, the provisions of subsection 192(6) of Bill C-139 must be considered in so far as determining in which taxation year the New Rules will apply to the corporations in question. ...

We also considered David G. Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business.  ...

It has been said that a bad debt is a debt which the creditor, after having personnally considered the relevant factors insofar as they are applicable to each particular debt, honestly and reasonably determines to be uncollectible at the and of the fiscal year when the determination is required to be made.       ...

As a result, the overload penalties were considered, by the Court, to be "unintentional violations" and as such were not "outrageous transgressions of public policy". 2. ...

This CDE would be allocated to the investors, in the partnership pursuant to subparagraph 66.2(5)(a)(iv) on December 31, 1989 and would be considered as CDE of the investor on December 31, 1989 under these circumstances. ...

It is our view that a corrected adjusted net loss balance for CMT purposes for a statute-barred taxation year could be considered when determining a future taxation year’s eligible loss balance if that adjusted net loss had not been correctly reported because an error was made by the taxpayer. ...

Any repayment required by section 8 of the CRB Act is considered payable on the balance-due day for the year. ...

Position: Yes, a Burkina Faso SARL should generally be considered to be a corporation for purposes of the Act. ...

While not necessarily conclusive, where a product provides for a death benefit or constitutes an annuity arrangement, it may be suggestive that it could be considered a life insurance policy for the purposes of the Act. ...