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Michel Lambert 957-8962 Le 11 octobre 2002 2002-015682 ROUND-TABLE ON FEDERAL TAXATION APFF- 2002 CONVENTION Question 12 Tax credit for Quebec motion picture production Section 1029.8.35 of the Taxation Act allows a tax credit for Quebec motion pictures. ...

Adèle St-Amour 998-0290 Le 11 octobre 2002 2002-015689 ROUND-TABLE ON FEDERAL TAXATION APFF- 2002 CONVENTION Question 19 Loan for buyback of shares and payment of dividends We have been informed that the federal Department of Justice and the CCRA are currently studying the case law and the position pertaining to the deductibility of interest in the context of a loan to buy back shares and pay dividends (Trans-Prairie, Ludco, Singleton, Penn Ventilator, etc.). ...

Nancy Deslandes 957-8961 Le 11 octobre 2002 2002-015708 ROUND-TABLE ON FEDERAL TAXATION APFF- 2002 CONVENTION Question 38 Medical expenses and dependant children Mr. ...

La convention entre actionnaires signée par les actionnaires de CANCO n'accorde aucun droit immédiat ou futur, conditionnel ou non qui permettrait de déclencher l'application de l'alinéa 251(5)b). ...

Second, we note, also for information purposes, that although a tax treaty between Canada and another country may affect the taxation of gains on the disposition of property (and could also possibly affect the taxation of something like the "provident fund" income), Canada does not currently have a tax treaty with Hong Kong and Canadian courts have confirmed that the income tax convention between Canada and China does not apply to Hong Kong. ...

The parties are not aware of any “tax benefit” under the Act (as that term is defined in subsection 245(1)) that will result from any of the proposed transactions described herein, in and by themselves, other than the reduction of any liability for Canadian income tax that Investor might have on any gain on its disposition of the XXXXXXXXXX Shares, as a result of the application of the provisions of the Convention. ...

With respect to her claim, Individual B was considered by the Court to have provided assistance in the administration and marketing roles, maintained the company accounts, attended XXXXXXXXXX conventions and, from time to time, Individual B would discuss ideas in respect of the business with Individual A. ...

Each of USHoldco, USco1, USco2 and USco3 is a resident of the United States under Canadian common law principles as well as being a resident of the United States for the purposes of the Canada-United States Income Tax Convention, 1980. ...

Tax Convention (the Treaty) provides limited tax relief with respect to gifts made by Canadian residents to certain U.S. organizations that are not qualified donees. ...

Income Tax Convention. M.N.R. v. Tara Exploration & Development Company Limited [1972] CTC 328 (S.C.C.), at p. 331, illustrates the principle that income is not attributable to a country where, in relation to a particular income-producing activity, no decisions are taken by management and no one is authorized to take such decisions. ...