Words and Phrases - "agreement"
16 November 2001 Internal T.I. 2001-0095617 F - ACCORD ECRIT RETROACTIF GARDE D'ENFANTS
After finding that a letter signed by the two separated spouses did not constitute an “agreement” for purposes of the “support amount” and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118 - Subsection 118(5) | subsequent letter was not an agreement eliminating a support obligation in respect of one of the two children | 217 |
19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules
In response to several enquiries from auditors on the meaning of “agreement” for the purposes of ss. 7 and 110(1)(d), the Directorate first...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) | no agreement to issue shares if vesting in employer's discretion | 263 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(2) | no agreement if allocation of shares in trustee's discretion | 284 |
Transalta Corporation v. The Queen, 2012 DTC 1106 [at 3044], 2012 TCC 86
Near the beginning of each year, the taxpayer would notify each of its executives that an award of units (within a specifed range) would be made...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | past services | 42 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 61 |
Mansfield v. The Queen, 83 DTC 5136, [1983] CTC 97 (FCTD), aff'd 84 DTC 6535, [1984] CTC 547 (FCA)
In 1972, the taxpayer and other employees of a private company were offered convertible debentures of their employer which, in the case of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 80 |
Hovasse v. The Queen, 2011 DTC 1115 [at 622], 2011 TCC 143 (Informal Procedure)
When a married couple separated, the husband's support payments made pursuant to their "summary of mediated agreements" were deductible. The...
McAnulty v. The Queen, 2001 DTC 942 (TCC)
The time at which the taxpayer's employer agreed to issue shares to her was the time at which the president called her to his desk and told her...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | stock option agreement effective time of oral agreement (not yet ratified by board) | 147 |
R. v. Kakfwi, 99 DTC 5639, [1999] 4 CTC 264 (FCA)
In finding that s. 90 did not apply to salary paid to an Indian band chief pursuant to a federal funding program known as Band Support Funding,...