20(1)(e)

TN-44-Exchangeable Debentures

Exchangeable Debentures: Paragraph 20(1)(f) Question 1 At the Canadian Tax Foundation’s 2008 annual conference,[Footnote 18] the CRA was asked to provide its views in respect of the application of paragraph 20(1)(f) to exchangeable debentures in light of the Federal Court of Appeal decision in Tembec Inc. et al. v. The Queen.[Footnote 19] The CRA was not prepared to comment at that […]

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IT99R5- Legal and Accounting Fees

NO.: IT-99R5 (Consolidated)  DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT  Legal and Accounting Fees REFERENCE: Paragraph 18(1)(a) (also sections 9 and 239; subsections 13(12), 20(9), and 40(1); paragraphs 6(1)(f), 6(1)(j), 8(1)(b) and (c), 20(1)(b), (e) and (cc), 56(1)(b), (l) and ( l.1), 60(o) and (o.1) and the definitions of “cumulative eligible capital” and “eligible capital expenditure” in subsection

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