Search - convention

To complete the pattern, the 1979 set of financial statements filed is reproduced: JOSEPH GLEDDIE STATEMENT OF INCOME For The Year Ended December 31, 1979 (Prepared Without Audit) (Based On Information Supplied By Client) (For Income Tax Purposes Only) REVENUE Professional — Cash Credits $ 31,302.96 Add: Accounts Receivable at December 31, 1979 2,430.00 Total Revenue $ 33,732.96 EXPENSES Accounting and Legal $ 496.00 Advertising and Promotion 1,897.70 Automotive (Business Portion): Gas and Oil 454.36 Repairs and Maintenance 813.70 Parking 635.50 Insurance 477.00 Capital Cost Allowance (Schedule) 8,179.90 Convention Expenses 1,311.04 Loan Interest and Charges 4,903.77 Office In The House Expenses (Business Portion): Office Supplies and Stationery $1,1,79.24 Telephone 468.50 Utilities 309.85 Mortgage Interest 2,987.91 Property Taxes 441.29 Repairs and Maintenance 43.88 Management Fees 275.39 Insurance 82.00 5,788.06 Total Expenses $24,957.03 Net Income For Tax Purposes 18,775.93 CAPITAL COST ALLOWANCE SCHEDULE Proceeds Class U.C.C. ... As to the “Advertising and Promotion” and the “Convention Expenses”, their current value (during the years in question) is in great doubt — simply put, Mr Gleddie could not take on any outside contracts. ...

Tremblay participated in the "Americana" convention. His goal was to meet clients and potential partners there. During the convention, he became acquainted with company representatives for GSI and Englobe. ...

)   [12]     Section 81 of the Income Tax Act reads:   81. (1) There shall not be included in computing the income of a taxpayer for a taxation year,       (a) an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada; …   [13]     In Mitchell v. ...

Furthermore, pursuant to the Canada-United States Tax Convention, he was not qualified to be exempt from US taxation on employment income earned there. ...

(«Rasquier»), une corporation qui exploitait un centre d'accueil privé conventionné, situé à Charlesbourg, Québec. ...

The Respondent relies on the definition of “prescribed expenditure” in Regulation  2902:   2902    For the purposes of the definition “qualified expenditure” in subsection 127(9) of the Act, a prescribed expenditure is   (a)        an expenditure of a current nature incurred by a taxpayer in respect of   (i)         the general administration or management of a business, including   (A)       administrative salary or wages and related benefits in respect of a person whose duties are not all or substantially all directed to the prosecution of scientific research and experimental development, except to the extent that such expenditure is described in subsection 2900(2) or (3)   (B)       a legal or accounting fee, (C)       an amount described in any of paragraphs 20(1)(c) to (g) of the Act, (D)       an entertainment expense, (E)       an advertising or selling expense, (F)       a conference or convention expense, (G)       a due or fee in respect of membership in a scientific or technical society or organization, and (H)       a fine or penalty, or (ii)        the maintenance and upkeep of premises, facilities or equipment to the extent that such expenditure is not attributable to the prosecution of scientific research;   [11]     Counsel for the Appellant argued that the amount $18,618 paid to Deacur & Co. was directly attributable to the Appellant’s prosecution of SR&ED within Regulation 2900(2)(c) because that payment would not have been incurred if such prosecution had not occurred. ...

Although it was pleaded that the assessments, for technical reasons, were invalid and that they were contrary to the Canada-Netherlands Tax Convention these points were not pursued at trial. ...

For example, professional licence fees and dues, convention expenses, continuing education expenses, professional malpractice insurance, etc., paid for by the PMC will not be eligible for “mark-up”. ...

(However, under Article XI of the Canada-United States Income Tax Convention in force at that time, this tax is limited to 15 per cent). ...

There shall not be included in computing the income of a taxpayer for a taxation year,   (a) Statutory exemptions- an amount that is declared to be exempt from income tax by any other enactment of Parliament, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada;   Jurisprudence – The Connecting Factors Test   [4]      In Williams v. ...