(e)-(x)

Paragraph 12(1)(e) - Reserves for certain goods and services, etc.

Cases

Argus Holdings Ltd. v. Canada, 2000 DTC 6681 (FCA)

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Sears Canada Inc. v. The Queen, 89 DTC 5039 (FCA)

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Words and Phrases
deducted

Dominion of Canada General Insurance Co. v. The Queen, 86 DTC 6154, [1986] 1 CTC 423 (FCA)

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Words and Phrases
deducted
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) 104

Abed Estate v. The Queen, 82 DTC 6099, [1982] CTC 115 (FCA)

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See Also

Dubawn Holdings Inc. v. The Queen, 94 DTC 1252 (TCC)

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Words and Phrases
deducted

Administrative Policy

24 March 1995 T.I. 950729 (C.T.O. "Sale Price of Shares - Closing")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 32

Paragraph 12(1)(f) - Insurance proceeds expended

Administrative Policy

4 March 2015 External T.I. 2014-0550761E5 F - 44(1) et disposition partielle

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property part of building treated as former business property 153
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1) partial destruction of building 187
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (f) insurance proceeds received for destruction of part of building: compensation for property damaged rather than destroyed 70

Paragraph 12(1)(g) - Payments based on production or use

Cases

Canada v. Larsen, 99 DTC 5757 (FCA)

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The Queen v. Mel-Bar Ranches, 89 DTC 5189 (FCTD)

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Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (FCA)

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Porta-Test Systems Ltd. v. The Queen, 80 DTC 6046, [1980] CTC 71 (FCTD)

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Lackie v. The Queen, 79 DTC 5309, [1979] CTC 389 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 74.1 - Subsection 74.1(1) 58

MNR v. Gault, 65 DTC 5157, [1965] CTC 261 (Ex Ct)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Nature of Income 99

Gingras v. MNR, 63 DTC 1142 (Ex Ct)

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Tax Topics - Statutory Interpretation - Reciprocity 98

Minister of National Revenue v. Wain-Town, 52 DTC 1138, [1952] CTC 147, [1952] 2 S.C.R. 377

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Words and Phrases
royalties

See Also

Deragon v. The Queen, 2015 TCC 294

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) sales proceeds reduced by subsequent price adjustment clause but included conditional sales proceeds 463
Tax Topics - General Concepts - Effective Date proceeds reduced by subsequent settlement pursuant to price adjustment clause 195

Smith v. The Queen, 2011 DTC 1332 [at 1870], 2011 TCC 461

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Wright v. The Queen, 2003 DTC 763 (TCC)

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Rouleau v. MNR, 91 DTC 120 (TCC)

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289018 Ontario Ltd. v. MNR, 87 DTC 38 (TCC)

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Pacific Pine Co., Ltd. v. MNR, 61 DTC 95 (TAB)

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Mr. R. v. MNR, 50 DTC 398 (ITAB)

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Administrative Policy

2015 Ruling 2015-0589471R3 - Earnout

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Words and Phrases
determinable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Safe Income Determination Time safe income determination time for a subsequent contemplated dividend was immediately before that dividend 512
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) s. 85(1) rollover available on dirty s. 85 exchange 90
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) utilization of safe income as earned through a contemplated succession of dividends of all the annual earnings 172
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) transactions for using s. 7 rules on sale of non-treasury shares 200

10 March 2015 External T.I. 2014-0552551E5 F - Vente du droit d'exploiter une sablière

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Words and Phrases
profit à prendre
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate application of capital gains criteria on woodlots to sale of rights to extract sand 49
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property sale of rights to extract sand could be considered sale of qualified farm or fishing property 154

12 January 2015 External T.I. 2014-0555071E5 - POD subject to earn-out

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital proceeds of goodwill on sale of wind turbine development project 225
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - cumulative Canadian exploration expense - Element G proceeds of wind turbine development project 141
Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) wind turbine development project 102

27 August 2014 External T.I. 2014-0529221E5 F - Changement de méthode pour déclarer un gain

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Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2) administrative policy on earnout calculation was not an election 122

24 February 2014 External T.I. 2013-0505391E5 F - Clause de earnout renversé

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) a sale price that is subject to a reverse earnout is not considered to be payable after the year (no reserve) 187

14 May 2013 External T.I. 2013-0480561E5 F - Méthode de recouvrement du coût

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20 December 2011 External T.I. 2011-0423771E5 - Payments Based on Production or Use

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23 March 2011 Internal T.I. 2010-0389081I7 F - Disposition of a resource property

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - cumulative Canadian development expense - Element F proceeds from mineral claims sale included undiscounted deferred cash proceeds, but might exclude share consideration until issued; purchaser’s CEE obligation excluded 370
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) proceeds included full (undiscounted) deferred cash proceeds, but might exclude share consideration (with volatile market price) until issued 167
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) full undiscounted amount of future cash consideration to be included as an amount receivable 184

11 May 2001 Internal T.I. 2001-007236 -

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24 September 1997 T.I. 971836

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20 January 1994 Memorandum 932972

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30 December 1992 T.I. (Tax Window No. 27, p. 5, ¶2321)

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2 September 1992 Memorandum (Tax Window, No. 24, p. 17, ¶2222)

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IT-462 "Payments Based on Production or Use" 1 January 1995 (Archived)

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IT-426R "Shares Sold Subject to an Earnout Agreement" 26 Ocober 2004 (Archived)

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Articles

Warren Pashkowich, Daniel Bellefontaine, "Participation-Based Payments: What Are They and How are They Taxed", 2017 Conference Report (Canadian Tax Foundation), 9:1-25

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Scheuermann, "Income and Commodity Tax Aspects of Acquiring and Exploiting Technology", 1991 Conference Report, c. 45.

Richardson, "Purchase and Sale of a Business: Income Tax Aspects of Warranties, Price Adjustments and Earn-Outs", 1990 Corporate Management Tax Conference Report, pp. 10:11-10:23.

Paragraph 12(1)(i) - Bad debts recovered

See Also

Beck v. MNR, 92 DTC 1784 (TCC)

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Paragraph 12(1)(j) - Dividends from resident corporations

Cases

Banner Pharmacaps NRO Ltd. v. Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)

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Tax Topics - General Concepts - Payment & Receipt promissory note accepted as payment 133
Tax Topics - Income Tax Act - Section 133 - Subsection 133(8) - Non-Resident-Owned Investment Corporation dividend received when note issued/such note not a money-lenidng business 219

Paragraph 12(1)(l.1) - Partnership — interest deduction add back

Administrative Policy

28 July 2015 External T.I. 2015-0567811E5 - Thin cap rules for members of a partnership

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(7) sale by Cancos of their partnership interests part-way through year did not eliminate their proportionate pick-up of partnership debt 142

Articles

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

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Paragraph 12(1)(n.3) - Retirement compensation arrangement

Administrative Policy

17 December 2010 External T.I. 2009-0338841E5 - Characterization of Income from an RCA

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31 March 1995 External T.I. 5-950295 -

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Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(2) 47

Paragraph 12(1)(o)

Cases

Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA)

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Words and Phrases
receivable

Paragraph 12(1)(p)

Administrative Policy

26 June 2014 External T.I. 2014-0523871E5 F - Revenu d'entreprise agricole

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming legume germination production as farming 36
Tax Topics - Income Tax Act - Section 12 - Subsection 12(10.2) government contributions and accrued interest in AgriInvest and Agri-Québec accounts are taxable when withdrawn 144

Paragraph 12(1)(r) - Inventory adjustment

Administrative Policy

93 CPTJ - Q.5

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Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 29

Paragraph 12(1)(t) - Investment tax credit

Administrative Policy

15 August 2014 External T.I. 2014-0522541E5 - Application of 12(1)(x)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) timing of receipt of apprenticeship training tax credit 71

Paragraph 12(1)(x) - Inducement, reimbursement, etc.

Cases

Imperial Oil Resources Limited v. Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037

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Iron Ore Co. of Canada v. The Queen, 2001 DTC 5411, 2001 FCA 224

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Canada v. Canada Safeway Limited, 98 DTC 6060 (FCA)

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Words and Phrases
refund reimbursement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing 31

The Queen v. CCLC Technologies Inc., 96 DTC 6527 (FCA)

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Westcoast Energy Inc. v. The Queen, 91 DTC 5334 (FCTD), briefly aff'd 92 DTC 6253 (FCA)

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Words and Phrases
reimbursement
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Tax Topics - Statutory Interpretation - Resolving Ambiguity 78

See Also

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) amounts replaced reduced lease income rather than contributing to leased vehicles' cost 217
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing capital tax accrued from day to day 206
Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income 248
Tax Topics - Income Tax Act - Section 9 - Computation of Profit surcharges received by lessor at lease termination for excess use were income 242
Tax Topics - Income Tax Act - Section 9 - Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified 199

Henco Industries Limited v. The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192

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Tax Topics - General Concepts - Evidence parol evidence rule not applying to surrounding evidence/press releases admitted 227
Tax Topics - General Concepts - Fair Market Value - Land deference to taxpayer's figure within appraiser's range of values 105
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital payment to withdraw from business was not an eligible capital amount 138
Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) land ceased to be inventory through sterilization rather than business cessation 176
Tax Topics - Income Tax Act - Section 3 compensation payment for destroyed business was non-taxable 163
Tax Topics - Income Tax Act - Section 9 - Compensation Payments compensation payment for destroyed business was non-taxable 163

Immunovaccine Technologies Inc. v. Canada, 2014 DTC 5119 [at 7309], 2014 FCA 196, aff'g 2013 DTC 1101 [at 531], 2013 TCC 103

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Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance "government assistance" generally encompasses amounts advanced on non-commercial terms 243
Tax Topics - Statutory Interpretation - Ejusdem Generis definition ending in "any other form of assistance" precluded a narrow reading 74

Morguard Corporation v. The Queen, 2012 DTC 1099 [at 2959], 2012 TCC 55, aff'd 2013 DTC 5009 [at 5554], 2012 FCA 306

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Alberta Power (2000) Ltd. v. The Queen, 2009 DTC 1514, 2009 TCC 412

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Tax Topics - General Concepts - Ownership person with the benefits and burdens of ownership was the beneficial owner 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 54
Tax Topics - Income Tax Act - Section 9 - Compensation Payments amount was received in respect of impaired capital asset (which then was transferred to payor) rather than for lost profits 107

PSC Elstow Research Farm Inc v. The Queen, 2009 DTC 168, 2008 TCC 694

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Hudson Bay Mining and Smelting Co., Ltd. v. The Queen, 2003 DTC 173 (TCC)

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Coughlan v. The Queen, 2001 DTC 719 (TCC)

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Bois Aisé de Roberval Inc. v. The Queen, 99 DTC 380 (TCC)

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Quincaillerie Laberge Inc. v. The Queen, 95 DTC 155 (TCC)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition amendment of agreement did not entail its transfer 140

Hill v. The Queen, 94 DTC 1078 (TCC), aff'd 95 DTC 5225 (FCA)

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Tyoxide Canada Inc. v. The Queen, 93 DTC 1499 (TCC)

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Everett's Truck Stop Ltd. v. The Queen, 93 DTC 965 (TCC)

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Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) 92

St. John Dry Dock & Shipbuilding Co. v. MNR (1944), 2 DTC 663 (Ex Ct)

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Higgs v. Olivier (1952), 33 TC 136 (C.A.)

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Words and Phrases
in the course of

Administrative Policy

12 March 2012 External T.I. 2011-0425361E5 F - Assistance paid by franchisor

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business reimbursements of business expenses increase income 175

26 May 2016 IFA Roundtable Q. 6, 2016-0642081C6 - German Organschafts

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) profit transfer payments by German sub to its German parent deemed to be dividends under s. 90(2) 303
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) profit transfer payments made by a German sub to German parent are s. 90(2) dividends not within s. 95(2)(a)(ii)(B) after 2016 147
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) German profit transfer payment to loss subsidiary is contribution of capital 154

16 February 2016 External T.I. 2015-0618601E5 - Earned or Unearned Revenue

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Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(2) no deferral of lump sum received on signing 15-year supplier loyalty agreement 176
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) no deferral for amount included under s. 56.4(2) or 12(1)(x) 120

12 September 2012 Annual CTF Roundtable, 2012-0453381C6 - 2012 CICA Conference

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Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount tax debt not a commercial debt obligation 105
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt forgiveness of source deductions on income account 102

15 August 2014 External T.I. 2014-0522541E5 - Application of 12(1)(x)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(t) federal apprenticeship job creation tax credit 85

15 September 2014 Internal T.I. 2014-0545001I7 - Grants paid to employers of reservists

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Tax Topics - Income Tax Act - Section 9 - Nature of Income compensation for reservist costs 38

21 March 2011 External T.I. 2011-0395011E5 - Deductibility of Ontario SAT

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6 May 2009 External T.I. 2008-0295581E5 F - Bourses et aide financière aux médecins

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) specialized training grants made to unlicensed medical residents to encourage them to settle in remote areas were s. 56(1)(n) fellowships 150

2008 Ruling 2006-0217541R3 - Stock Option Reimbursement

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2004 Ruling 2004-007680 -

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26 July 2001 External T.I. 2001-008329 -

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2001 Ruling 2000-003987 -

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18 September 2000 External T.I. 2000-002946 -

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15 November 1999 External T.I. 5-992458 -

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) prepaid rent on related-party building transfer 31

7 July 1999 T.I. 982411 [ITC received when deducted]

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5 February 1998 T.I. 972953 [loan repayable out of revenues]

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1997 Ruling 970769 [benefit on redemption not an inducement]

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29 October 1996 External T.I. 5-962632 -

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11 January 1996 T.I. 952684 (C.T.O. "Alberta Government Assistance - Small Business Equity")

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1 February 1994 T.I. 933226 [investor rebate inclusion under s. 12(2.1)]

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1994 A.P.F.F. Round Table, Q. 41

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94 CPTJ - Q. 1

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2 December 1993 T.I. 932103 (C.T.O. "Taxation of GST and other Rebates")

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5 November 1993 T.I. 932008

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27 October 1993 T.I. 931992 [inclusion re forgivable loan at time of advance]

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26 February 1993 T.I. (Tax Window, No. 29, p.17, ¶2440)

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10 February 1993 T.I. 921720C (See also 13 January 1993 T.I. 923304)

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8 February 1993 Memorandum (Tax Window, No. 29, p.18, ¶2437)

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December 1992 B.C. Tax Executives Institute Round Table, Q.13 (October 1993 Access Letter, p. 481)

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"Farm Support Payments: A Paper by the Rulings Directorate addressed to Agriculture Canada - 1992" (September 1993 Access Letter, p. 426).

7 November 1992 Memorandum (Tax Window, No. 27, P. 21, ¶2354, October 1993 Access Letter, p. 478)

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12 October 1992 T.I. 922359 (September 1993 Access Letter, p. 406, ¶C9-283)

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30 November 1991 Round Table (4M0462), Q. 8.2 - Subscription to Preferred Shares by a Government Body (C.T.O. September 1994)

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30 November 1991 Round Table (4M0462), Q. 8.1 - Acquisition of a Business (C.T.O. September 1994)

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91 C.R. - Q.19

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1 August 1991 T.I. (Tax Window, No. 7, p. 18, ¶1382)

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26 July 1991 T.I. (Tax Window, No. 7, p. 2, ¶1376)

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20 March 1991 T.I. (Tax Window, No. 1, p. 2, ¶1158)

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17 January 1991 Memorandum (Tax Window, No. 1, p. 4, ¶1150)

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14 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 23, ¶1056)

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30 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 17, ¶1067)

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19 September 1990 Memorandum ACC 96248

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90 C.P.T.J. - Q.14

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(2.2) 35

11 May 1990 Memorandum (October 1990 Access Letter, ¶1494)

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30 May 1990 T.I. (October 1990 Access Letter, ¶1459)

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5 February 1990 T.I. (July 1990 Access Letter, ¶1318)

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5 January 1990 T.I. (June 1990 Access Letter, ¶1252)

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3 January 1990 T.I. (June 1990 Access Letter, ¶1253)

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89 C.M.TC - "Leasing Costs" - "Application of Paragraph 12(1)(x) of the Act to the Tenant"

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88 C.R. - Q.16

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88 C.R. - Q.46

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87 C.R. - Q.17

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86 C.R. - Q.8

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86 C.R. - Q.10

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Articles

Lewin, "Tax Treatment of Lease Inducement and At-Risk Rules and the New Limited Recourse Debt Rules", 1995 Corporate Management Tax Conference Report, c. 5.

Carr, "Lease Inducement Payments", 1993 Conference Report, C. 32.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments 0

Subparagraph 12(1)(x)(iv)

Administrative Policy

20 May 2014 External T.I. 2013-0516121E5 F - Debt forgiveness

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(2.2) s. 12(1)(x)(iv) inclusion from BIA settlement of GST interest and penalties could be offset against related expense 149
Tax Topics - Income Tax Act - Section 248 - Subsection 248(26) unremitted GST and QST were not obligation "issued" by debtor 94
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Commercial Debt Obligation BIA settlement of unremitted GST interest 121
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt BIA settlement of unremitted GST on sales was on capital account 78

20 November 2012 External T.I. 2012-0440031E5 F - Quebec Tax Credit for Production of Performances

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8 December 2010 External T.I. 2010-0375921E5 - Subsection 20(24)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) income to both vendor and purchaser if no election/payment by set-off/no prescribed form 127

8 October 2004 Roundtable, 2004 APFF Roundtable, Q. 34, 2004-0087021C6 - Repayment of financing costs

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Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39

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Subpargraph 12(1)(x)(viii)

See Also

Ritchie v. The Queen, 2018 TCC 113

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Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) signing bonus assimilated to proceeds under the signed contract 107

Paragraph 12(1)(z.7)