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Although 501 treated the acquired IP as depreciable property, it considered that Taxation Act s. 99 (equivalent to ITA s. 13(7)(e)) did not apply to reduce the capital cost to it of the acquired IP because, in SherWeb’s hands, the IP had been eligible capital property rather than depreciable property. ...

He stated (at para. 31): Although [43]-[47] of the 2008 Commentary are new, it is clear from [7] of the Commentary that they were considered appropriate for inclusion by the OECD because they were not in conflict with earlier versions of the Commentary. … On that basis, the 2008 Commentary, although new, would be admissible as an aid to the construction of Article 8(2) of the 1976 Convention which, as I have explained, adopted the wording of Article 7(2). ...

In concluding that this exclusion applied, Riverin JCQ found that: A qualified investment professional (an experienced CFA) devoted himself full-time to managing Boeckh’s portfolio; The portfolio had what he considered to be a high turnover (of around 30%, with the percentage of securities held for over two years, ranging from 31% to 45%, and those held for over five years ranging from 14% to 24%). ...

He considered the construction period to commence with the receipt of the building permit and to end with the point of substantial completion, being the point at which “there was some minor work to be done that did not prevent the house from being used for the purpose for which it was built.” ...

Agence du revenu du Québec, 2021 QCCQ 12822-- summary under Paragraph 2900(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 2900- Subsection 2900(2)- Paragraph 2900(2)(b) the applicable salaries of employees engaged in SR&ED but who did not record their time could not be recognized Although the ARQ accepted that the taxpayer was carrying on SR&ED, the taxpayer had failed to establish with any convincing evidence what proportion of the remuneration of its employees qualified under Regulation 230R1 (s. 230)(b) – equivalent to federal Reg. 2900(2)(b)) as being amounts that could reasonably be considered to be in respect of the prosecution of such SR&ED. ...

It remains to be considered whether the present case falls within that rule. ...

Agence du revenu du Québec, 2023 QCCQ 3350-- summary under Subsection 18(12) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(12) the relative business use represented by a home office using the home’s gross rather than net area In deducting his home office expenses, the taxpayer determined the portion of his home that was used in his business of providing electrical engineering services (28%), which he calculated by dividing the square-foot area of the three rooms that he used in that business by the net square footage of his home, which was the area of the two floors (main floor and basement) as measured by the exterior dimensions, minus the areas taken up by the walls and minus the area of common areas (stairwells and hallways), which he considered to be used pro rata for business and personal use. ...

S. 1010.0.2 provides that, notwithstanding the expiration of the period to file objections, the Quebec Minister may, within one year of a federal reassessment “make a reassessment for the sole purpose of taking into account elements that may be considered to relate to that assessment or reassessment.” ...

The King, 2024 TCC 76-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) amounts that in fact had been paid were not deemed to have been payable notwithstanding any illegality CRA considered that the trustees of a family trust had improperly delegated their fiduciary powers to other individuals (the Rémillard Brothers) in violation of the trust deed and Art. 1275 of the Civil Code, so that the trust determinations to make distributions based on such improper delegation were a nullity, with the result that the distribution amounts were not “payable” as required by s. 104(6). ...

A sum is considered certain when it can be made certain. By this, I take it, is meant where it can be determined by computation. ...