(q)-(vv)

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14 March 2017 External T.I. 2016-0627311E5 F - Deduction of contribution to an IPP or RCA

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements a mooted RCA providing supplementary pension benefits must be similar to the IPP which it supplements 253

18 November 2014 External T.I. 2012-0457981E5 - Restorative payment to registered plan

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Tax Topics - Income Tax Act - Section 204.1 - Subsection 204.1(2.1) employer restorative payment to RRSP or RPP to compensate for tort 77
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) employer restorative payment to RRSP or RPP to compensate for tort 109
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(i) employer restorative payment to RRSP or RPP to compensate for tort 153

IC 72-13R8 "Employees' Pension Plans"

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2018 Ruling 2017-0720901R3 - Use of a Surety Bond by RCA

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Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax - Paragraph (a) use of surety bonds rather than LCs to secure SERP benefits 483

Articles

Paragraph 20(1)(v.1)

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8 June 1994 Internal T.I. 5-941462 -

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Paragraph 20(1)(z) - Cancellation of lease

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Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5371, [1979] CTC 262 (FCA)

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30 May 1991 Ruling 3-910967 -

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Articles

Atlas, "Income Tax Issues in Real Estate Leasing", under "Lease Cancellation", 1989 Corporate Management Tax Conference, p. 3:27

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Paragraph 20(1)(z.1) - Idem [Cancellation of lease]

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29 May 1990 T.I. S-9748 (October 1990 Access Letter, ¶1456)

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22 May 1990 T.I. (October 1990 Access Letter, ¶1457)

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Paragraph 20(1)(aa) - Landscaping of grounds

Cases

Toronto College Park Ltd. v. The Queen, 94 DTC 6172 (FCTD)

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Words and Phrases
landscaping

Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122 (FCA)

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Forest Products Terminal Corp. Ltd. v. Minister of Municipal Affairs of the Province of New Brunswick (1986), * A.P.R. (NBQB)

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22 November 1991 T.I. (Tax Window, No. 13, p. 16, ¶1609)

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Articles

Atlas, "Income Tax Issues in Real Estate Leasing"

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Paragraph 20(1)(bb) - Fees paid to investment counsel

Cases

Canada v. Rio Tinto Alcan Inc., 2018 FCA 124

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Words and Phrases
commission specific shares
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management dealer and professional fees incurred by a public board in determining to make a bid, as contrasted to implementation, were currently deductible 336
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular was not a financial report 154

See Also

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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Words and Phrases
commission
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 228
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Wickham Estate v. The Queen, 2015 DTC 10125 [at 102], 2014 TCC 352 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management pro rata denial based on portfolio portion invested in RRIF 65
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(u) pro rata denial based on portfolio portion invested in RRIF 40

Vatcha v. MNR, 91 DTC 653 (TCC)

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Re Magna Training Centre (1987), 62 OR (2d) 540 (S.C.O.)

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Charron v. MNR, 87 DTC 98, [1987] 1 CTC 2135 (TCC)

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Bardsley Trust v. MNR, 82 DTC 1659, [1982] CTC 2642 (T.R.B.), rev'd on consent [see 83 C.T.J. 1013]

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No. 579 v. MNR, 58 DTC 734, 21 Tax ABC 21

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25 August 2014 External T.I. 2014-0526891E5 - Investment counselling fees for RDSP

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6 May 2014 CALU Roundtable, 2014-0523321C6 - 2014 CALU Conference

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security

14 February 2011 External T.I. 2010-0381561E5 - Deductibility of Trustee Fee

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23 March 2007 External T.I. 2006-0207071E5 - Investment Counsel Fees

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18 July 2006 Internal T.I. 2006-0170871I7 - Investment banker fees

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6 February 2002 External T.I. 2001-010560 -

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8 January 1997 Memorandum 963477

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11 July 1995 T.I. 951746 (C.T.O. "Fees Paid to Investment Counsel")

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22 April 1992 External T.I. 5-921033 -

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10 January 1992 Memorandum (Tax Window, No. 17, p. 17, ¶1773)

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6 November and 18 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 18, ¶1048)

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87 C.R. - Q.13

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81 C.R. - Q.22

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IT-238R2 "Fees Paid to Investment Counsel"

Paragraph 20(1)(cc) - Expenses of representation

See Also

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible 515
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 228
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Industries Perron Inc. (anciennement 3654419 Canada Inc.) v. The Queen, 2012 DTC 1072 [at 2836], 2011 TCC 433, aff'd 2013 FCA 176

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21 January 2016 CPA Personal Income Tax Roundtable Q. 7, 2016-0625731C6 F - Fees related to a voluntary disclosure

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(o) professional fees incurred after a voluntary disclosure is accepted commence to be deductible 143

22 May 2014 Ponoka Liason Meeting Roundtable, 2014-0528451C6 - Cost of Making Voluntary Disclosure

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees costs of voluntary disclosure incurred by business 74
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(o) costs of voluntary disclosure incurred by business 74

20 June 2007 Internal T.I. 2007-0233551I7 - Deductibility of Transaction Costs

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12 May 2000 Internal T.I. 2000-0001737 - EXPENSES OF REPRESENTATION

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16 November 1994 Memorandum 941467 (C.T.O. "Film Rights") (see also 3 November 1994 Memorandum 941171)

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29 October 1991 Memorandum (Tax Window, No. 12, p. 13, ¶1557)

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13 June 1991 T.I. (Tax Window, No. 4, p. 24, ¶1307)

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IT-99R4 "Legal and Accounting Fees"

IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences"

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Paragraph 20(1)(dd) - Investigation of site

Cases

Brooke Bond Foods Ltd. v. The Queen, 84 DTC 6144, [1984] CTC 115 (FCTD)

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Queen & Metcalfe Carpark Ltd. v. MNR, 74 DTC 6007, [1973] CTC 810 (FCTD), aff'd [1976] CTC xvi (FCA)

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Parker Brothers Textile Mills Limited v. The Queen, 2007 DTC 610, 2007 TCC 74

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Administrative Policy

86 C.R. - Q. 28

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Paragraph 20(1)(ee) - Utilities service connection

Cases

The Queen v. Guaranteed Homes Ltd., 78 DTC 6510, [1978] CTC 636 (FCTD)

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Tax Topics - Statutory Interpretation - Comparison of Provisions 53

See Also

Richcraft Homes Ltd. v. The Queen, 95 DTC 657 (TCC)

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Paragraph 20(1)(gg)

Cases

Bastion Management Ltd. v. The Queen, 95 DTC 5238 (FCA)

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Tax Topics - Statutory Interpretation - Purpose 80

Gay Lea Foods Co-operative Ltd. v. The Queen, 94 DTC 6285 (FCTD)

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Plaza Pontiac Buick Ltd. v. The Queen, 94 DTC 6058 (FCA)

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GSW Appliances Ltd. v. The Queen, 93 DTC 5502 (FCTD)

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The Queen v. Mattabi Mines Ltd., 89 DTC 5357 (FCTD), aff'd 92 DTC 6252 (FCA)

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Brault-Clement Inc. v. The Queen, 86 DTC 6277, [1986] 2 CTC 1 (FCTD), aff'd 92 DTC 6010 (FCA)

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Brault-Clement Inc. v. The Queen, 86 DTC 6277, [1986] 2 CTC 1 (FCTD), aff'd 92 DTC 6010 (FCA)

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The Queen v. Boehringer Ingelheim (Canada) Ltd., 85 DTC 5443, [1985] 2 CTC 211 (FCTD), aff'd 87 DTC 5442, [1987] 2 CTC 245 (FCA)

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Tax Topics - Income Tax Act - Section 10 - Subsection 10(2) 42

Saskatchewan Wheat Pool v. The Queen, 85 DTC 5034, [1985] 1 CTC 30 (FCA)

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Fraser v. London Sports Car Centre Ltd., [1984] BTC 409 (HC), aff'd [1985] BTC 547 (C.A.)

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trading stock

Paragraph 20(1)(hh) - Repayments of inducements, etc.

Administrative Policy

1993 A.P.F.F. Round Table, Q.15

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Tax Topics - General Concepts - Payment & Receipt 65

Paragraph 20(1)(ss)

Administrative Policy

2003 Ruling 2003-00503030 - AT-RISK BENEFIT AND ENVIRONMENTAL TRUST

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Tax Topics - Income Tax Act - Section 211.6 - Subsection 211.6(1) - Qualifying Environmental Trust reclamation trust for re-opened mine partly funded by investor partnership 159