text stringlengths 3 1.63k | embedding list | __index_level_0__ int64 0 15.2k |
|---|---|---|
of that payment was to significantly alter the value of the interest of any specified shareholder of the corporation the fair market value of the stock dividend shall except to the extent that it is otherwise included in computing that income under any of paragraphs and to be included in computing the income of that pe... | [
-0.07896821945905685,
0.06877472251653671,
-0.0033115835394710302,
-0.04313094541430473,
-0.04054749384522438,
0.024086197838187218,
0.09463705867528915,
0.02655073069036007,
0.06970487534999847,
0.0007616308867000043,
0.05186614394187927,
-0.04296179115772247,
0.01917886734008789,
-0.0478... | 200 |
the cost to a person of purchasing a property or service or an amount payable by a person for the purpose of leasing property is taken into account in determining an amount required under this section to be included in computing a income for a taxation year that cost or amount payable as the case may be shall include a... | [
-0.025756802409887314,
0.007635089568793774,
-0.010790341533720493,
-0.03899381682276726,
-0.0691748857498169,
0.08812179416418076,
0.13634958863258362,
0.011533326469361782,
0.06577496975660324,
0.03700840100646019,
0.03306570276618004,
-0.09195097535848618,
0.017215143889188766,
0.017727... | 201 |
partnership is deemed to be a member of the other benefit conferred by a corporation on an individual is a benefit conferred on a shareholder of the corporation a member of a partnership that is a shareholder of the corporation or a contemplated shareholder of the corporation except to the extent that the amount or val... | [
-0.02449639141559601,
-0.02699819579720497,
-0.007714257575571537,
-0.0495569221675396,
-0.0633757933974266,
0.0748862773180008,
0.12263469398021698,
-0.0021680567879229784,
0.0728534683585167,
-0.03205190598964691,
0.07688549906015396,
-0.04788066819310188,
0.04973749443888664,
0.01675676... | 202 |
of a foreign jurisdiction undergoes a division under those laws that results in all or part of its property and liabilities becoming the property and liabilities of one or more other corporations of which is referred to in this subsection as a and as a consequence of the division a shareholder of the original corporati... | [
-0.023694917559623718,
-0.054092902690172195,
0.057562388479709625,
-0.07391735166311264,
-0.028833329677581787,
0.01776031404733658,
0.05491670221090317,
-0.008625097572803497,
0.048932451754808426,
-0.007917465642094612,
0.10949832201004028,
-0.013672658242285252,
0.0293598510324955,
0.0... | 203 |
at the particular time and amount of the dividend in kind received by the shareholder in respect of an original share is deemed to be equal to the fair market value immediately after the particular time of the new shares acquired by the shareholder at the particular time in respect of the original share and any case wh... | [
-0.08603721112012863,
-0.03688091039657593,
0.08147098124027252,
-0.048647183924913406,
-0.01642606407403946,
0.05521669611334801,
0.09422861039638519,
0.04579555243253708,
0.059729110449552536,
0.045181117951869965,
0.10288531333208084,
-0.015778739005327225,
0.033277783542871475,
0.02190... | 204 |
original proceeds of disposition Marginal debt a person than a corporation resident in or a partnership than a partnership each member of which is a corporation resident in is shareholder of a particular corporation with a shareholder of a particular corporation or member of a partnership or a beneficiary of a trust th... | [
0.0026702359318733215,
-0.039568595588207245,
-0.013374644331634045,
-0.049382664263248444,
-0.055970750749111176,
0.021523119881749153,
0.0892757698893547,
0.04124186560511589,
0.10936640202999115,
-0.011157174594700336,
0.040038879960775375,
-0.04647937789559364,
0.00008333364530699328,
... | 205 |
the particular corporation does not deal at length Marginal loan or indebtedness the purposes of subsection and subject to subsection 17 pertinent loan or indebtednessmeans a loan received or an indebtedness incurred at any time by a corporation this subsection referred to as the or by a partnership of which the subjec... | [
-0.013346238993108273,
0.012039490044116974,
0.038786500692367554,
-0.052505336701869965,
-0.06544598191976547,
0.045931246131658554,
-0.021543491631746292,
0.021090494468808174,
0.04247383400797844,
0.011581447906792164,
0.03104635514318943,
-0.07839848101139069,
0.019106397405266762,
-0.... | 206 |
owing to the qualifying Canadian partnership all the members of the qualifying Canadian partnership and a corporation that controls the CRIC jointly elect in writing under this subparagraph in respect of the amount owing and file the election with the Minister on or before the date of the CRIC for its taxation year in ... | [
-0.047090958803892136,
0.04483545571565628,
0.05003434792160988,
-0.04207564890384674,
-0.06388840079307556,
0.12418990582227707,
0.0017331348499283195,
0.00679872278124094,
0.03475455194711685,
0.027114683762192726,
0.049456994980573654,
-0.06504034996032715,
0.049861762672662735,
-0.0189... | 207 |
which the election is required by paragraph to be made and ending on the day the election is made Marginal purposes of this subsection subsection section 17 1 and subsection Canadian partnership at any time in respect of a CRIC means a partnership each member of which is at that time the CRIC or another corporation res... | [
-0.02449044957756996,
-0.0281040221452713,
0.051132407039403915,
-0.06810058653354645,
-0.04570566490292549,
0.11171483248472214,
-0.00018456301768310368,
-0.03933747857809067,
0.03242477402091026,
0.0036823838017880917,
0.044753625988960266,
-0.009684520773589611,
0.012149267829954624,
-0... | 208 |
as theintended has an amount outstanding as or on account of a debt or other obligation to pay an amount this subsection and subsections to referred to as theshareholder to a person or partnership this subsection and subsections to referred to as theimmediate would not in the absence of this subsection and subsection a... | [
-0.023400219157338142,
-0.0220795925706625,
0.000194055144675076,
0.018247058615088463,
-0.002627067733556032,
0.03124791570007801,
0.040857456624507904,
-0.018220623955130577,
0.060526374727487564,
-0.0015780156245455146,
0.04540873318910599,
-0.051273051649332047,
0.00961510743945837,
-0... | 209 |
anticipated that all or a portion of the debt or other obligation would become owing or remain outstanding or a specified right in respect of a particular property that was granted directly or indirectly by a person or partnership and existence of the specified right is required under the terms and conditions of the pa... | [
-0.010365191847085953,
0.014209739863872528,
0.005638347938656807,
-0.017957985401153564,
0.015455614775419235,
0.03387967124581337,
0.04050525277853012,
0.018619725480675697,
0.05146599933505058,
0.0382135771214962,
0.034259770065546036,
-0.006114947609603405,
0.01941828988492489,
0.00062... | 210 |
that is owed by a funder than an ultimate to an ultimate funder under a funding arrangement in respect of the shareholder debt or fair market value of a particular property in respect of which an ultimate funder has granted a specified right to a funder than an ultimate under a funding arrangement in respect of the sha... | [
-0.030914807692170143,
-0.01816062070429325,
-0.010759913362562656,
-0.056829243898391724,
0.013983780518174171,
0.008695295080542564,
0.07513073086738586,
0.048919565975666046,
0.08243664354085922,
0.05852959677577019,
0.03668150678277016,
-0.027520794421434402,
0.016277052462100983,
0.04... | 211 |
or in part amount owing in respect of a debt or other obligation owing to the particular ultimate funder by a funder than an ultimate under a funding arrangement in respect of the shareholder debt is repaid in whole or in part or is a decrease in the fair market value of a property in respect of which a specified right... | [
0.005364185199141502,
0.0052108741365373135,
0.04392380267381668,
-0.057090263813734055,
0.01366997230798006,
0.032816626131534576,
0.07825356721878052,
0.04303715005517006,
0.055417999625205994,
0.04641374573111534,
0.0438041165471077,
-0.029669927433133125,
0.04109765216708183,
-0.003462... | 212 |
the particular time amount outstanding as or on account of a debt or other obligation that is owed by a funder than an ultimate to an ultimate funder under a funding arrangement in respect of the shareholder debt or fair market value of a particular property in respect of which an ultimate funder has granted a specifie... | [
-0.03777412697672844,
0.012224119156599045,
0.024671029299497604,
-0.0580814853310585,
0.03136451169848442,
-0.015516873449087143,
0.015149081125855446,
0.09049972146749496,
0.09406817704439163,
0.03808525949716568,
0.05175253003835678,
-0.042548567056655884,
0.02996572107076645,
0.0362200... | 213 |
by subsection to have been received by the intended borrower from the particular ultimate funder before the particular and total amount of the deemed repayments referred to in paragraph is equal to the absolute value of that negative amount Marginal arrangement definitions following definitions apply in this subsection... | [
-0.03699693828821182,
-0.007272713351994753,
-0.014054447412490845,
-0.027014750987291336,
-0.015253914520144463,
-0.00371691701002419,
0.040576912462711334,
0.032211363315582275,
0.08533497899770737,
0.024427779018878937,
0.0738234892487526,
-0.04851758852601051,
0.05093097314238548,
-0.0... | 214 |
the funder instead of the immediate funder de fonds Marginal s not to apply persons does not apply to indebtedness between persons Marginal s not to apply ordinary lending business does not apply to a debt that arose in the ordinary course of the business or a loan made in the ordinary course of the ordinary business o... | [
-0.03288431093096733,
-0.009875569492578506,
-0.018004076555371284,
-0.05490316450595856,
-0.042794838547706604,
-0.009866704232990742,
0.05062169209122658,
0.0012873696396127343,
0.10236271470785141,
-0.012841559946537018,
0.07278552651405334,
-0.015132548287510872,
0.00965853501111269,
-... | 215 |
for the habitation the lender or creditor is a particular corporation in respect of an employee of the particular corporation or of another corporation that is related to the particular corporation to enable or assist the employee to acquire from the particular corporation or from another corporation related to the par... | [
-0.06431523710489273,
0.02734280750155449,
0.027361370623111725,
-0.05996762961149216,
-0.06740361452102661,
0.03466383367776871,
0.03216347098350525,
0.011054285801947117,
0.02405954711139202,
-0.029905933886766434,
0.09124477952718735,
-0.011457542888820171,
0.058068081736564636,
-0.0314... | 216 |
trust where lender or creditor is a private corporation is the settlor and sole beneficiary of the sole purpose of the trust is to facilitate the purchase and sale of the shares of the corporation or of another corporation related to the corporation for an amount equal to their fair market value at the time of the purc... | [
-0.06351295113563538,
-0.02536170184612274,
-0.012258466333150864,
-0.040851395577192307,
-0.07024586200714111,
0.00804575439542532,
0.03731395676732063,
-0.012006739154458046,
0.1022384911775589,
-0.02987680397927761,
0.09443449974060059,
-0.04165980592370033,
0.06770440191030502,
-0.0440... | 217 |
section an individual who is an employee of a partnership is deemed to be a specified employee of the partnership where the individual is a specified shareholder of one or more corporations that in total are entitled directly or indirectly to a share of any income or loss of the partnership which share is not less than... | [
-0.07871966809034348,
0.01824192889034748,
0.027766287326812744,
-0.06300770491361618,
-0.08415181189775467,
0.057890620082616806,
0.06821507960557938,
0.005860304459929466,
0.03158315271139145,
0.020831260830163956,
0.04655279964208603,
-0.05612465739250183,
-0.03113277070224285,
-0.00166... | 218 |
laws of the country in which the corporation was resident deductible in computing the amount for the year on which the corporation was liable to pay income or profits tax imposed by the government of that country Marginal benefit the purposes of subsection the value of the benefit to be included in computing a income f... | [
-0.05510237067937851,
-0.0033083551097661257,
0.030766690149903297,
-0.07706905901432037,
-0.014134276658296585,
0.07067249715328217,
0.11494992673397064,
0.08272099494934082,
0.009310005232691765,
-0.0006975255091674626,
0.07328703999519348,
-0.0011906522559002042,
0.04938079044222832,
0.... | 219 |
deemed by section 80 4 to be a benefit received by a person or partnership in a taxation year the amount is deemed for the purpose of subsection to be a benefit conferred in the year on a shareholder unless subsection or paragraph applies to the amount Marginal on small business development bonds 15 amount received by ... | [
-0.061822559684515,
0.11821816861629486,
0.03500431776046753,
-0.11261098086833954,
-0.0036270632408559322,
0.02477259933948517,
0.07151700556278229,
0.03445282205939293,
-0.028598519042134285,
0.04720380902290344,
0.13015885651111603,
-0.06280340999364853,
-0.029177667573094368,
0.0633769... | 220 |
of paragraph 15 it shall when paid be deemed to have been paid as a taxable and for the purposes of paragraph the taxable income for any taxation year that includes a period throughout which the obligation was a small business development bond but issuer was not an eligible small business corporation or or substantiall... | [
-0.050024501979351044,
0.08025462180376053,
0.001379277091473341,
-0.034573957324028015,
-0.04577915370464325,
0.06279075890779495,
0.06818440556526184,
0.018314730376005173,
-0.037636324763298035,
0.014633859507739544,
0.090428926050663,
-0.035480719059705734,
-0.029679229483008385,
-0.00... | 221 |
admissible exploitant une petite joint electionmeans an election that is made in prescribed form containing prescribed information jointly by the issuer of an obligation and the person who is the holder of the obligation at the time of the election that is filed with the Minister by the holder and in which the holder a... | [
-0.030083348974585533,
0.1133727878332138,
-0.027923917397856712,
-0.01953906938433647,
-0.041098449379205704,
0.08416968584060669,
0.021012241020798683,
0.03707927465438843,
-0.037512339651584625,
0.021623607724905014,
0.002918432466685772,
0.001189820352010429,
0.09003309160470963,
-0.05... | 222 |
VIII s qualifying debt obligationof a corporation at a particular time means an obligation that is a bond debenture bill note mortgage hypothecary claim or similar obligation issued after February 25 1992 and before 1995 principal amount of which is not less than 000 or more than 000 is issued for a term of not more th... | [
-0.0487901009619236,
-0.01034976914525032,
0.004828123841434717,
-0.041142307221889496,
-0.10294649749994278,
-0.0406775064766407,
0.011567791923880577,
0.027268825098872185,
0.016350850462913513,
-0.042334239929914474,
0.06874128431081772,
-0.02680441178381443,
0.02981729619204998,
-0.043... | 223 |
that small business development bondat any time means obligation that is at that time a qualifying debt obligation issued after 1981 and before 1988 by a private corporation in respect of which a joint election was made within 90 days after the later of its issue date and March 30 1983 obligation that is at that time a... | [
-0.04604027047753334,
0.08637271076440811,
0.012558817863464355,
-0.0586504302918911,
-0.059343669563531876,
0.05813641473650932,
-0.005056688562035561,
0.028526006266474724,
-0.03561314195394516,
-0.008388803340494633,
0.0916079506278038,
-0.02323823608458042,
0.010444841347634792,
-0.030... | 224 |
not been filed pour le de la petite specified 1994 c 7 Sch | [
-0.042367592453956604,
0.08660468459129333,
-0.013463047333061695,
-0.05638109892606735,
0.054872170090675354,
0.09959327429533005,
-0.06291055679321289,
0.08066339790821075,
-0.0007528341375291348,
-0.0001568990555824712,
0.027401579543948174,
-0.07204174995422363,
-0.05612730607390404,
-... | 225 |
VIII s Marginal borrowed any other provision of this Act an amount paid or payable by a taxpayer pursuant to a legal obligation to pay interest on borrowed money used for the purpose of acquiring a small business development bond shall be deemed to be an amount paid or payable as the case may be on borrowed money used ... | [
-0.06892518699169159,
0.03214395418763161,
-0.0264112688601017,
-0.029510894790291786,
-0.05412224307656288,
0.03870367258787155,
0.07496423274278641,
0.036873165518045425,
0.0353112667798996,
0.016878752037882805,
0.06542963534593582,
-0.020362962037324905,
0.03628692403435707,
0.00082742... | 226 |
the issuer had at or before the particular time made a joint election in respect of any small business development bond or small business bond as the case may be for the purposes of this section the issuer shall be deemed not to be an eligible small business corporation in respect of the obligation Marginal 15 does not... | [
-0.06172415241599083,
0.09615682065486908,
-0.01925826072692871,
-0.050895024091005325,
-0.03838249668478966,
0.0690666064620018,
-0.021725939586758614,
0.03623063117265701,
0.0018955559935420752,
-0.006289110518991947,
0.14627206325531006,
-0.04508180916309357,
0.014637820422649384,
0.048... | 227 |
VIII s Marginal on small business bond 15 amount received by a taxpayer as or on account of interest on a small business bond shall except for the purposes of Part IV be deemed to have been received as a taxable dividend from a taxable Canadian corporation Marginal for small business bonds an individual or a partnershi... | [
-0.0532340332865715,
0.07015825808048248,
-0.007891695015132427,
-0.045114561915397644,
-0.033536188304424286,
0.028481492772698402,
0.03938862308859825,
0.03878264129161835,
0.005518626421689987,
0.012014604173600674,
0.08435937762260437,
-0.012138676829636097,
-0.020427245646715164,
0.01... | 228 |
the tax otherwise payable under this Part by the issuer for that taxation year an amount equal to of the amount of interest paid or payable on the method regularly followed in computing the in respect of the bond for that period Marginal this section eligible issuerat any time means individual than a who is resident in... | [
-0.04753285273909569,
0.07469815015792847,
-0.007351393345743418,
-0.034451235085725784,
-0.037511419504880905,
0.08778209239244461,
0.053683727979660034,
-0.0012636499013751745,
0.0068354676477611065,
0.03012068197131157,
0.05944425240159035,
-0.024771837517619133,
0.027041120454669,
0.01... | 229 |
of an obligation and the person who is the holder of the obligation at the time of the election that is filed with the Minister by the holder and in which the holder and the issuer elect that the provisions of this section apply to that majority interest 1998 c 19 s qualifying debt obligationof an issuer at a particula... | [
-0.022346338257193565,
0.038523461669683456,
-0.010024640709161758,
-0.011517848819494247,
-0.07409719377756119,
-0.015595227479934692,
0.014557156711816788,
0.03194878622889519,
0.003715864848345518,
-0.016783054918050766,
0.0697614848613739,
-0.0349925197660923,
0.0506870299577713,
-0.02... | 230 |
the issuer is in default or could reasonably be expected to default on a debt incurred in the course of the business and held by a person with whom the issuer was dealing at length or where the issuer is a partnership by a person with whom each member of the partnership was dealing at length and it is issued in whole o... | [
-0.07038310915231705,
0.09086304903030396,
0.006659953389316797,
-0.020550742745399475,
-0.09202834218740463,
0.07507682591676712,
-0.013223826885223389,
0.01761781983077526,
0.027951091527938843,
-0.00003558476601028815,
0.06030554324388504,
-0.009959562681615353,
0.01309995073825121,
0.0... | 231 |
obligation and the manner in which the issuer and the holder have treated the obligation for the purposes of this Act and holder files with the Minister a joint election in respect of the obligation within 90 days after the date of notification by the Minister that a joint election in respect of the obligation has not ... | [
-0.048699524253606796,
0.08922802656888962,
0.014305644668638706,
-0.04927165061235428,
-0.03984871134161949,
0.09348876774311066,
0.09516046196222305,
0.03996548801660538,
0.015700647607445717,
0.012593017891049385,
0.06984138488769531,
0.01220695674419403,
0.030441058799624443,
-0.024872... | 232 |
under this Part by the shall be read as a reference to the otherwise payable under this Part by each member of the and each member shall add to that tax otherwise payable under this Part for the taxation year that includes the period described in paragraph 15 the amount that can reasonably be regarded as that share of ... | [
-0.07112551480531693,
0.09072989225387573,
-0.02060041017830372,
-0.06010913476347923,
-0.07736212015151978,
0.05021803081035614,
0.04196356609463692,
0.05320565402507782,
-0.023604638874530792,
-0.022165674716234207,
0.08408447355031967,
-0.042840760201215744,
-0.015144087374210358,
0.036... | 233 |
individual is a member or corporation that is associated with a corporation referred to in clause or the issuer is a partnership the total of all amounts each of which is the principal amount outstanding immediately after that time in respect of obligation that is a small business bond issued by partnership individual ... | [
0.010702716186642647,
0.05995276942849159,
-0.05004865303635597,
0.011180512607097626,
-0.07071896642446518,
-0.0008024033159017563,
0.06632016599178314,
0.0380459763109684,
0.05398719012737274,
-0.011357340961694717,
0.025958439335227013,
-0.020064041018486023,
-0.023701125755906105,
0.00... | 234 |
VIII s Marginal and capital combined under a contract or other arrangement an amount can reasonably be regarded as being in part interest or other amount of an income nature and in part an amount of a capital nature the following rules part of the amount that can reasonably be regarded as interest shall irrespective of... | [
-0.06064794585108757,
0.03141262009739876,
-0.044252704828977585,
-0.06383066624403,
-0.05607995390892029,
-0.008177475072443485,
0.03935172036290169,
0.09641839563846588,
-0.013709614984691143,
0.037098005414009094,
0.06426866352558136,
-0.03844068944454193,
0.015864653512835503,
0.003346... | 235 |
tax under section 149 a person not carrying on business in Canada or a government municipality or municipal or other public body performing a function of government obligation was issued for an amount that is less than the principal amount of the obligation interest stipulated to be payable on the obligation expressed ... | [
-0.07574077695608139,
0.045530375093221664,
-0.01267219614237547,
-0.06646303087472916,
-0.07087323814630508,
-0.019339246675372124,
0.014427064917981625,
0.018796084448695183,
-0.014770652167499065,
0.06704778969287872,
0.07624192535877228,
-0.0411607027053833,
-0.029522160068154335,
0.02... | 236 |
conditional on the exercise of any such exceeds the annual rate determined under paragraph by more than thereof the amount by which the principal amount of the obligation exceeds the amount for which the obligation was issued shall be included in computing the income of the first owner of the obligation who is a reside... | [
-0.07915303111076355,
0.0737152248620987,
0.01987268030643463,
-0.07605849206447601,
-0.07332788407802582,
-0.051492176949977875,
0.024317800998687744,
0.028607118874788284,
-0.027886992320418358,
0.04050060361623764,
0.08095649629831314,
-0.08085757493972778,
-0.012350054457783699,
0.0033... | 237 |
on the amount for which the obligation was issued annual rate shall if the terms of the obligation or any agreement relating thereto conferred on the holder thereof a right to demand payment of the principal amount of the obligation or the amount outstanding as or on account of the principal amount as the case may be b... | [
-0.07182544469833374,
0.053019411861896515,
0.012435169890522957,
-0.03718363866209984,
-0.10414242744445801,
-0.024945292621850967,
-0.031920675188302994,
0.018232563510537148,
0.014638072811067104,
0.07536417245864868,
0.06308440119028091,
-0.07582475244998932,
-0.01594194397330284,
0.00... | 238 |
of section 149 from tax under this Part on all or part of the taxable income and whom the obligation is a capital property for the taxation year in which the owner acquired the obligation Marginal s does not apply does not apply to any amount received by a taxpayer in a taxation year an annuity or satisfaction of the r... | [
-0.06059814244508743,
0.057518843561410904,
-0.02864990569651127,
-0.0876731276512146,
-0.054902609437704086,
-0.0009480596636421978,
0.11968473345041275,
0.020201873034238815,
-0.03458179906010628,
0.0003559596079867333,
0.025401270017027855,
-0.05597629025578499,
0.013975090347230434,
0.... | 239 |
payable in respect of the year by the taxpayer as interest in respect of the obligation and amount determined in prescribed manner shall be deemed to be received and receivable by the taxpayer in the year as interest in respect of the and taxpayer pays or credits an amount in respect of an amount determined under subpa... | [
-0.043623100966215134,
0.005735257640480995,
0.03896460309624672,
-0.05219658464193344,
-0.06970727443695068,
-0.019767820835113525,
0.011436139233410358,
-0.007768143434077501,
-0.004290218465030193,
0.030712919309735298,
0.006921994499862194,
-0.0475105345249176,
0.040375180542469025,
0.... | 240 |
in the course of carrying on a business through a permanent establishment in Canada as defined by regulation any income from which is subject to tax under this Part who owns the property and with whom the lessee was dealing at length this section referred to as the for a term of more than one year if the lessee and the... | [
-0.004090103320777416,
0.06071237102150917,
0.044383857399225235,
-0.05087880417704582,
-0.07902354001998901,
0.056574732065200806,
-0.011513247154653072,
-0.0022188115399330854,
0.016000661998987198,
0.05585718899965286,
0.06391754746437073,
-0.0027296135667711496,
0.016167091205716133,
0... | 241 |
value of the property at that shall be deemed to accrue on the principal amount of the borrowed money outstanding from time to time compounded not in advance at the prescribed rate in effect the earlier of time if any before the particular time at which the lessee last entered into an agreement to lease the property an... | [
0.002632656367495656,
0.10444668680429459,
-0.006201792508363724,
-0.03663770481944084,
-0.0817798301577568,
0.025386622175574303,
-0.0229495819658041,
0.0367303304374218,
0.0331321619451046,
0.07930685579776764,
0.07835600525140762,
-0.04071744158864021,
0.03422700613737106,
0.02575892582... | 242 |
16 applied firstly on account of interest on principal secondly on account of interest on unpaid interest and thirdly on account of unpaid principal if any and the amount if any by which any such payment exceeds the total of those amounts shall be deemed to be paid or payable on account of interest and any amount deeme... | [
0.016495810821652412,
0.11362676322460175,
0.037460003048181534,
-0.04690288379788399,
-0.06329714506864548,
-0.007128271274268627,
0.03604124113917351,
0.007768097333610058,
0.009266847744584084,
0.0879463255405426,
0.10245893150568008,
-0.058408383280038834,
0.035892385989427567,
-0.0039... | 243 |
as the case may be by the lessee on account of the principal amount of the borrowed money and amounts paid or payable by or on behalf of the lessee in respect of the cancellation or assignment of the lease or the sublease of the the purposes of subsections and each amount paid or payable by or on behalf of the lessee t... | [
0.01340510230511427,
0.09445711225271225,
0.0008588951313868165,
-0.006644965149462223,
-0.052092816680669785,
0.01011872198432684,
0.045162271708250046,
0.011339517310261726,
0.03384867310523987,
0.08461920917034149,
0.04379061236977577,
-0.06620954722166061,
0.06842216104269028,
-0.00102... | 244 |
of the and the lessee elects under this subsection in respect of a property and at any time after the lease was entered into the owner of the property is a person who does not hold the lease in the course of carrying on a business through a permanent establishment in Canada as defined by regulation any income from whic... | [
0.00986209511756897,
0.0809096097946167,
0.04572891816496849,
-0.0388907715678215,
-0.06180423125624657,
0.05259785056114197,
0.004576470237225294,
-0.016633687540888786,
0.04333551973104477,
0.0684456005692482,
0.057436469942331314,
-0.014619052410125732,
0.027671076357364655,
-0.00004784... | 245 |
the owner of the property for a term of more than one year and assignee and the owner of the property jointly elected under subsection 16 in respect of the property with their returns of income under this Part for their respective taxation years that include the particular time Marginal to subsection 16 where at any pa... | [
-0.007292260881513357,
0.09540822356939316,
0.0666104108095169,
-0.06646936386823654,
-0.061495326459407806,
0.04842306673526764,
0.027956653386354446,
0.019332079216837883,
-0.003944998141378164,
0.05231988802552223,
0.07491548359394073,
-0.05792994052171707,
0.05549022927880287,
0.006622... | 246 |
subsection 16 where at any time a particular corporation that has made an election under subsection 16 in respect of a lease assigns the lease reason of an amalgamation the meaning assigned by subsection or the course of the of a Canadian corporation in respect of which subsection applies to another corporation with wh... | [
-0.011498648673295975,
0.020308390259742737,
0.04894986003637314,
-0.044032398611307144,
-0.04517773911356926,
0.03243226557970047,
0.014430975541472435,
-0.017800388857722282,
0.024775147438049316,
-0.012215148657560349,
0.054046425968408585,
-0.008793530985713005,
0.047881294041872025,
0... | 247 |
the original property Marginal property the purposes of subsection 16 where at any particular time addition or alteration this subsection referred to as is made by a lessor to a property this subsection referred to as the of the lessor that is the subject of a lease lessor and the lessee of the original property have j... | [
0.004140837583690882,
0.059290479868650436,
0.030719580128788948,
-0.04988398402929306,
-0.036282338201999664,
0.024652982130646706,
-0.05081092566251755,
-0.004422551486641169,
0.015262652188539505,
0.03182337060570717,
0.06765526533126831,
-0.034883901476860046,
0.07484487444162369,
0.03... | 248 |
particular time additional property shall be deemed not to be prescribed property and excess referred to in paragraph 16 shall be deemed to be an amount payable by the lessee for the use of or the right to use the additional property Marginal of lease the purposes of subsection 16 where at any time lease this subsectio... | [
-0.021167581900954247,
0.05880854278802872,
0.01745506189763546,
-0.03349733352661133,
-0.09072978794574738,
0.050284359604120255,
0.026493361219763756,
0.00816163420677185,
0.03653360530734062,
0.05392879992723465,
0.07542453706264496,
-0.0654878094792366,
0.02348552644252777,
0.004933709... | 249 |
income for the year as on account of in lieu of or in satisfaction of interest in respect of the debt amount received or receivable by the corporation from a trust that is included in computing the income for the year or a subsequent taxation year and that can reasonably be attributed to interest on the debt for the pe... | [
-0.07298276573419571,
0.04770581051707268,
0.01122375950217247,
-0.04726522043347359,
-0.052764199674129486,
-0.004157477058470249,
0.05987297371029854,
0.014227618463337421,
0.02701801061630249,
0.0073913391679525375,
0.007965479977428913,
-0.061463482677936554,
0.035525619983673096,
-0.0... | 250 |
the original debt is an amount referred to in paragraph and because of the amount referred to in paragraph the debt is deemed to be owed by the person referred to in paragraph and original debt was owing by an intermediate lender to an initial lender or by an intended borrower to an intermediate lender the meanings of ... | [
-0.025144075974822044,
-0.0024271877482533455,
0.044406261295080185,
-0.025287428870797157,
-0.05335315316915512,
0.005393597763031721,
0.029119929298758507,
0.054993435740470886,
0.06413964182138443,
0.033672962337732315,
0.03203856199979782,
-0.0204959437251091,
0.04360498487949371,
-0.0... | 251 |
particular person or partnership than a corporation resident in and is reasonable to conclude that the amount or a portion of the amount became owing or was permitted to remain owing to the particular person or partnership because corporation resident in Canada made a loan or transfer of property or particular person o... | [
-0.020167874172329903,
0.014269069768488407,
0.03839300945401192,
-0.05635005235671997,
-0.056442879140377045,
0.03469754382967949,
0.05517372861504555,
0.029936781153082848,
0.06521067023277283,
0.011850470677018166,
0.04121195152401924,
-0.049224212765693665,
0.04517768695950508,
0.02834... | 252 |
the particular partnership are not related as the case may be terms or conditions made or imposed in respect of the amount owing determined without reference to any loan or transfer of property by a corporation resident in Canada described in paragraph in respect of the amount owing are such that persons dealing at len... | [
-0.008189305663108826,
-0.012370775453746319,
0.03957932069897652,
-0.07263839989900589,
-0.05750627443194389,
0.032824382185935974,
0.04352862387895584,
0.027030890807509422,
0.018156928941607475,
0.0011430894955992699,
0.06784430891275406,
-0.06300666928291321,
0.07767853885889053,
0.040... | 253 |
apply in respect of the amount owing to the partnership that proportion of the amount owing to the partnership at that time that fair market value of the interest in the partnership at that time is of fair market value of all interests in the partnership at that time Marginal rule loan through trust the purpose of this... | [
0.010377181693911552,
0.02701471373438835,
-0.009397821500897408,
-0.06776740401983261,
-0.10289370268583298,
0.029994424432516098,
0.050153110176324844,
0.03382844105362892,
0.05285623297095299,
0.03716734051704407,
0.03165453299880028,
-0.07475884258747101,
0.06392481923103333,
0.0360548... | 254 |
of the amount owing to the trust an amount equal to the amount owing to the trust Marginal rule loan to partnership the purpose of this section where a particular partnership owes an amount at any time to any person or any other partnership this subsection referred to as the each member of the particular partnership is... | [
-0.011511605232954025,
-0.018077824264764786,
0.01834079809486866,
-0.08045855909585953,
-0.05429576709866524,
0.05858723074197769,
0.05656453222036362,
0.0012805975275114179,
0.07232659310102463,
0.02737327851355076,
0.049125511199235916,
-0.019632529467344284,
0.03928392380475998,
0.0101... | 255 |
a corporation resident in Canada for a taxation year of the corporation in respect of an amount owing to the corporation by a person if the person is a controlled foreign affiliate of the corporation throughout the period in the year during which the amount is owing to the extent that it is established that the amount ... | [
-0.025390297174453735,
-0.04257018119096756,
0.003927507437765598,
-0.05162122845649719,
-0.05160804092884064,
0.023117434233427048,
0.07773284614086151,
0.015248578041791916,
-0.002786454977467656,
0.023295212537050247,
0.06609317660331726,
0.0014672542456537485,
0.04509332403540611,
0.01... | 256 |
foreign accrual property income for that or in the course of an active business as defined in subsection carried on by the affiliate throughout the period that began when the amount owing arose and that ended at the earlier of the end of the year and the time at which the amount was repaid Marginal money applies in res... | [
-0.02720644697546959,
-0.0586426742374897,
0.01667684316635132,
-0.023111332207918167,
0.003915983252227306,
0.022145280614495277,
0.0732787549495697,
0.008022748865187168,
0.04228377714753151,
-0.003272289875894785,
0.08370575308799744,
-0.028611332178115845,
0.06527139246463776,
0.038051... | 257 |
time at which it became a controlled foreign affiliate of the particular corporation unpaid purchase price is in respect of the property and the period that began when the unpaid purchase price became owing by the affiliate and ended when the unpaid purchase price was so paid the property had been used principally to e... | [
-0.011527537368237972,
0.009878071956336498,
0.0333038792014122,
-0.04502399265766144,
-0.019394302740693092,
0.049796950072050095,
0.08239974081516266,
-0.0046873497776687145,
0.021594064310193062,
0.04389267414808273,
0.11709652096033096,
0.008816581219434738,
0.031530145555734634,
-0.00... | 258 |
of the business carried on by the and terms and conditions in respect of the amount owing are such that persons dealing at length would have been willing to enter into them at the time that they were entered into Marginal of whether related and controlled foreign affiliate status the purpose of this section in determin... | [
0.029131485149264336,
-0.02521510049700737,
-0.005502968095242977,
-0.04536730423569679,
-0.06358373165130615,
0.070696622133255,
0.11470768600702286,
0.017358681187033653,
0.03694610670208931,
0.0032603645231574774,
0.06133321300148964,
-0.0065728058107197285,
0.07831183820962906,
0.00876... | 259 |
time Marginal of whether related the purpose of this section in determining whether persons are related to each other at any time each settlor in respect of a trust other than a trust is deemed to own the shares of a class of the capital stock of a corporation owned by the trust at that time Marginal of whether persons... | [
-0.022653959691524506,
-0.08268524706363678,
-0.02003193087875843,
-0.04328392446041107,
-0.0450190007686615,
0.054809294641017914,
0.04908214136958122,
-0.02141454629600048,
0.07008398324251175,
-0.030894368886947632,
0.08911707997322083,
0.03387320414185524,
0.030386656522750854,
0.03855... | 260 |
each member of which is this subsection referred to as the loan made by the intermediate lender to the intended borrower is deemed to have been made by the initial lender to the intended borrower the extent of the lesser of the amount of the loan made by the initial lender to the intermediate lender and the amount of t... | [
-0.03287152200937271,
-0.015750929713249207,
0.023643802851438522,
-0.05600999295711517,
-0.051076218485832214,
0.0241558738052845,
-0.001199854537844658,
0.0014917035587131977,
0.024648260325193405,
-0.01839221641421318,
0.05373464152216911,
-0.006071326322853565,
0.0679045096039772,
-0.0... | 261 |
those persons would at that time be controlled foreign affiliates of the corporation resident in and of subsection subsection would not apply to the corporation resident in Canada in respect of the amount that would but for this subsection have been deemed to have been owing at that time to the corporation resident in ... | [
0.02415594831109047,
-0.09941187500953674,
0.0033622949849814177,
-0.012335613369941711,
-0.048176974058151245,
0.055161554366350174,
0.0936722382903099,
-0.020158100873231888,
0.030998321250081062,
-0.013270861469209194,
0.08113076537847519,
-0.03790610656142235,
0.09343408048152924,
0.00... | 262 |
affiliate of the other corporation at that time Marginal rule where rights or shares issued acquired or disposed of to avoid tax the purpose of this section any person or partnership has a right under a contract in equity or otherwise either immediately or in the future and either absolutely or contingently to or to ac... | [
-0.03502081334590912,
-0.03419307991862297,
0.01282806508243084,
-0.07651080936193466,
-0.024999141693115234,
0.08586259931325912,
0.09960358589887619,
-0.02923485077917576,
0.012284377589821815,
-0.0019414311973378062,
0.1413276493549347,
0.0369589626789093,
0.033075250685214996,
0.007106... | 263 |
where the shares were unissued by the corporation immediately before the acquisition those shares are deemed not to have been issued Marginal definitions in this subsection apply in this section controlled foreign affiliate at any time of a taxpayer resident in Canada means a corporation that would at that time be a co... | [
0.005571939051151276,
-0.08816216140985489,
0.03735150769352913,
-0.02319699339568615,
-0.011683899909257889,
0.036173343658447266,
0.057191401720047,
0.007539027836173773,
0.022260747849941254,
0.0012312282342463732,
0.09937988966703415,
0.038721900433301926,
0.07111545652151108,
-0.02318... | 264 |
were dealing at length with each other at the time the loan was transfer of property than a transfer of property made for the purpose of acquiring shares of the capital stock of a foreign affiliate of a corporation or a foreign affiliate of a person resident in Canada with whom the corporation was not dealing at or pay... | [
-0.03170987218618393,
-0.000449359358754009,
0.05769968032836914,
-0.031178919598460197,
-0.060144491493701935,
0.01898042857646942,
0.08417277783155441,
-0.009482907131314278,
0.05060577020049095,
0.013577140867710114,
0.08709321916103363,
-0.0041509391739964485,
0.06787131726741791,
-0.0... | 265 |
directly or indirectly in any manner whatever to or for the benefit of the trust at or before that time other than where the person or partnership deals at length with the trust at that time loan made by the person or partnership to the trust at a reasonable rate of or transfer made by the person or partnership to the ... | [
-0.05686169117689133,
-0.002405140781775117,
0.006203589495271444,
-0.07359948009252548,
-0.07534731179475784,
0.03818206116557121,
0.012164799496531487,
0.0471101850271225,
0.053647205233573914,
-0.010114600881934166,
0.02996320091187954,
-0.0972093790769577,
0.05770896002650261,
-0.00695... | 266 |
amount of interest that would be included in computing the income of the CRIC for the year or of the qualifying Canadian partnership for the fiscal period as the case may be in respect of the amount owing for the particular period in the year or the fiscal period during which the amount owing was a pertinent loan or in... | [
-0.0379575677216053,
0.057438816875219345,
-0.035208962857723236,
-0.0670691654086113,
-0.06093955785036087,
0.03573213890194893,
0.02811533585190773,
0.05147745460271835,
0.06382295489311218,
0.0390501394867897,
0.017405500635504723,
-0.07934428006410599,
0.03408768028020859,
-0.007964844... | 267 |
and Marginal of control at any time a parent or group of parents referred to in section 212 3 acquires control of a CRIC and the CRIC was not controlled by a person or a group of persons not dealing with each other at length immediately before that time no amount is to be included under subsection in computing the inco... | [
-0.06127730756998062,
-0.015194677747786045,
-0.023366644978523254,
-0.07006191462278366,
-0.048517778515815735,
0.02159791626036167,
-0.003943029325455427,
0.05946565419435501,
0.029118187725543976,
0.02721361443400383,
0.07521712779998779,
-0.06607625633478165,
0.017497967928647995,
0.00... | 268 |
respect of Marginal limitation outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or Marginal outlay or loss outlay loss or replacement of capital a payment on account of capital or an allowance in respect of depreciation ... | [
-0.013860536739230156,
0.04714151471853256,
-0.03883061558008194,
-0.0159072857350111,
0.044539328664541245,
0.05543754622340202,
0.06956236064434052,
0.03922446072101593,
0.026859842240810394,
0.0069074626080691814,
0.0920153334736824,
0.0059648253954946995,
0.05338996276259422,
0.0182840... | 269 |
as or on account of the principal amount of any obligation described in paragraph except as expressly permitted by that Marginal on income bonds amount paid by a corporation as interest or otherwise to holders of its income bonds or income debentures unless the bonds or debentures have been issued or the income provisi... | [
-0.09327671676874161,
0.07021758705377579,
-0.017095183953642845,
-0.03087173029780388,
0.003181029111146927,
0.0796630010008812,
0.019865592941641808,
0.07472572475671768,
-0.04817147180438042,
-0.009464139118790627,
0.07967077940702438,
-0.009858077391982079,
-0.013240148313343525,
0.004... | 270 |
profit sharing plan deferred profit sharing plan or pooled registered pension plan or registered pension Marginal of recreational facilities and club dues outlay or expense made or incurred by the taxpayer after 1971 the use or maintenance of property that is a yacht a camp a lodge or a golf course or facility unless t... | [
-0.003210486611351371,
0.028830818831920624,
-0.042237259447574615,
-0.0036746528930962086,
0.029104050248861313,
0.12445802241563797,
0.06770136952400208,
-0.015924077481031418,
0.014641889370977879,
0.010354709811508656,
0.0498647578060627,
-0.0010898197069764137,
-0.025081442669034004,
... | 271 |
the benefit of one or more employees in respect of services to be rendered outside Marginal compensation arrangement as expressly permitted by paragraph contributions made under a retirement compensation Marginal life and health trust as expressly permitted by paragraph contributions to an employee life and health Marg... | [
-0.08932888507843018,
0.0763600543141365,
-0.008804451674222946,
-0.05683448538184166,
-0.04855802282691002,
0.12787020206451416,
0.11996100097894669,
0.008522874675691128,
0.013954387977719307,
0.011730575002729893,
0.09958821535110474,
-0.02444169484078884,
0.07692748308181763,
-0.000969... | 272 |
legal expenses incurred by it in collecting amounts owing to it on account of services rendered that would if the income of the corporation were from a business other than a personal services business be deductible in computing its Marginal re cancellation of lease amount paid or payable by the taxpayer for the cancell... | [
-0.028029607608914375,
0.07827364653348923,
0.005749974865466356,
-0.07250295579433441,
-0.02249038964509964,
0.07405742257833481,
0.11950331181287766,
0.03960708901286125,
0.04239905625581741,
0.05055516958236694,
0.07137909531593323,
-0.006397727876901627,
0.06486090272665024,
0.01716404... | 273 |
payable this Act than tax paid or payable under Part XII 2 or Part XII interest under Part IX of theExcise Tax Act interest under theAir Travellers Security Charge Act interest under theUnderused Housing Tax Act c 10 s interest under theSelect Luxury Items Tax c 10 s Marginal individual saving plans amount paid or paya... | [
0.02887585759162903,
0.04020864889025688,
-0.06995521485805511,
-0.05230305343866348,
0.019256150349974632,
0.05657152459025383,
0.15038394927978516,
0.02523180842399597,
-0.0047833677381277084,
0.035540495067834854,
-0.0010633303318172693,
-0.006969994865357876,
0.03181267902255058,
0.032... | 274 |
the cost at which the taxpayer acquired it or its fair market value at the end of the year whichever is lower property is described in subsection and property is not disposed of by the taxpayer in the and Marginal for shares amount referred to in subsection Marginal on certain interest and property tax paragraph in com... | [
0.001075269072316587,
0.05173342674970627,
0.03486895188689232,
-0.034606583416461945,
-0.014358454383909702,
0.019014153629541397,
0.053588852286338806,
0.015977367758750916,
-0.005298618692904711,
0.06156076490879059,
0.023288214579224586,
-0.08255460113286972,
0.04214191436767578,
-0.01... | 275 |
the taxpayer other than a business in the ordinary course of which land is held primarily for the purpose of resale or development or primarily for the purpose of gaining or producing income of the taxpayer from the land for the particular year except to the extent of the total of amount if any by which the gross reven... | [
-0.03343730419874191,
0.013759138062596321,
0.016574280336499214,
-0.06163015589118004,
-0.051376741379499435,
0.0036700789351016283,
0.06260504573583603,
0.026200756430625916,
0.02678469754755497,
0.05866208299994469,
0.06795526295900345,
-0.04352828115224838,
-0.02093644253909588,
0.0158... | 276 |
owned by the partnership before that day or on an obligation entered into by the taxpayer before April 1 1977 to pay for land owned by the partnership before that day and in a taxation year of the taxpayer either partnership has disposed of all or any portion of the land or taxpayer has disposed of all or any portion o... | [
-0.07143063098192215,
0.0511598140001297,
0.08305993676185608,
-0.033399343490600586,
-0.026901356875896454,
-0.02117106132209301,
0.004076303914189339,
0.000001381502443109639,
-0.040238719433546066,
0.09381060302257538,
0.04533052071928978,
-0.030354563146829605,
0.029284970834851265,
0.... | 277 |
of this section a base level deduction for a taxation year is the amount that would be the amount of interest computed at the prescribed rate for the year in respect of a loan of 000 000 outstanding throughout the year unless the corporation is associated in the year with one or more other corporations in which case ex... | [
-0.011999530717730522,
-0.007460636552423239,
0.025113139301538467,
-0.06953994184732437,
-0.046144384890794754,
-0.024585139006376266,
0.006147831212729216,
0.05947316810488701,
-0.0006972478004172444,
0.04124981164932251,
0.01784556172788143,
-0.06574132293462753,
-0.012158650904893875,
... | 278 |
of the corporations that are associated with each other in a taxation year has failed to file with the Minister an agreement as contemplated by subsection within 30 days after notice in writing by the Minister has been forwarded to any of them that such an agreement is required for the purpose of any assessment of tax ... | [
-0.031102199107408524,
-0.0033294083550572395,
0.058053042739629745,
-0.05808636173605919,
-0.032738517969846725,
0.05239592492580414,
0.021161293610930443,
0.0064730532467365265,
-0.026248065754771233,
0.03864535316824913,
0.06525502353906631,
-0.0782971903681755,
0.004633876029402018,
-0... | 279 |
the other corporation ending in that calendar year is subject to the application of paragraph an amount equal to its base level deduction for the first such taxation year determined without reference to paragraph and a corporation has a taxation year that is less than 51 weeks its base level deduction for the year is t... | [
-0.03585745394229889,
0.017820658162236214,
0.0686139464378357,
-0.0768132135272026,
-0.03686055541038513,
-0.008271732367575169,
0.04778692498803139,
-0.013751247897744179,
-0.040367066860198975,
0.021956147626042366,
0.03455866500735283,
-0.0765465646982193,
-0.038251303136348724,
-0.037... | 280 |
is or more to acquire land to be used or held by that person corporation or partnership otherwise than as described in paragraph or except where the assistance is in the form of a loan to that person corporation or partnership and a reasonable rate of interest on the loan is charged by the sur une dette concernant fond... | [
-0.010608249343931675,
0.048444703221321106,
0.029179876670241356,
-0.05131050571799278,
-0.013686292804777622,
0.012523159384727478,
0.07207736372947693,
0.01179059874266386,
0.018963772803544998,
0.04139745980501175,
0.05160893127322197,
-0.06400511413812637,
0.023018961772322655,
0.0193... | 281 |
renovation or alteration of a building by or on behalf of the taxpayer a person with whom the taxpayer does not deal at length a corporation of which the taxpayer is a specified shareholder or a partnership of which the share of any income or loss is or more and relating to the construction renovation or alteration or ... | [
-0.02131013385951519,
0.06918605417013168,
0.06396794319152832,
-0.04465540871024132,
-0.03883688896894455,
-0.0007482374203391373,
-0.021228812634944916,
0.009859020821750164,
0.0076751322485506535,
0.051132604479789734,
0.01565730571746826,
-0.040580980479717255,
-0.012985854409635067,
-... | 282 |
or more as the case may be Marginal costs the purposes of subsection costs relating to the construction renovation or alteration of a building or to the ownership of land include paid or payable by a taxpayer in respect of borrowed money that cannot be identified with a particular building or particular land but that c... | [
-0.006767951883375645,
0.023901324719190598,
0.022962456569075584,
-0.03483658283948898,
-0.021763328462839127,
-0.007451220415532589,
0.03860820084810257,
-0.000953495386056602,
0.058453720062971115,
0.07001344859600067,
-0.009604327380657196,
-0.0756857693195343,
-0.0019191240426152945,
... | 283 |
renovation or alteration of a building is completed at the earlier of the day on which the construction renovation or alteration is actually completed and the day on which all or substantially all of the building is used for the purpose for which it was constructed renovated or altered Marginal s does not apply does no... | [
-0.026943940669298172,
0.08297538012266159,
0.06399926543235779,
-0.04448864981532097,
-0.05959003418684006,
0.00890718586742878,
-0.041652780026197433,
-0.04271230101585388,
0.009403328411281109,
0.05707048252224922,
0.04778913035988808,
0.009451549500226974,
-0.034520626068115234,
0.0048... | 284 |
in respect of an outlay or expense made or incurred in 1988 in 1989 in 1990 and in 1991 Marginal does not apply in respect of an outlay or expense in respect of a building or the land described in subparagraph or in respect of the building the construction renovation or alteration of the building was in progress on Nov... | [
-0.017274487763643265,
0.0762149766087532,
0.07785804569721222,
0.015302165411412716,
-0.030462531372904778,
0.003919942304491997,
-0.09620682150125504,
0.029540861025452614,
0.00672282325103879,
0.03681730479001999,
0.003552596550434828,
0.030918633565306664,
0.023582132533192635,
-0.0075... | 285 |
before June 1 1982 and the installation of footings or other base support for the building commenced before 1983 and the construction renovation or alteration as the case may be of the building proceeds after 1982 without undue delay regard to acts of God labour disputes fire accidents or unusual delay by common carrie... | [
-0.026836413890123367,
0.03633420169353485,
0.10427259653806686,
0.03767114505171776,
0.0013325090985745192,
0.027856551110744476,
-0.08596601337194443,
-0.01977839507162571,
0.007636783644556999,
0.0155156459659338,
0.06182188540697098,
-0.019988080486655235,
-0.0055089183151721954,
-0.02... | 286 |
or a trust from a business than the Canadian banking business of an authorized foreign or property no deduction shall be made in respect of that proportion of any amount otherwise deductible in computing its income for the year in respect of interest paid or payable by it on outstanding debts to specified that amount i... | [
-0.022185752168297768,
-0.05304429680109024,
-0.020191416144371033,
-0.04617449268698692,
-0.09917878359556198,
-0.02673523873090744,
0.07193025946617126,
-0.004502198193222284,
0.04255111888051033,
-0.029448499903082848,
0.029942747205495834,
-0.05636304244399071,
0.030486462637782097,
-0... | 287 |
average of all amounts each of which is the contributed surplus than any portion of that contributed surplus that arose at a time when the corporation was or that arose in connection with a disposition to which subsection 212 applies or aninvestment as defined in subsection 212 to which subsection 212 at the beginning ... | [
0.019948873668909073,
-0.030158832669258118,
0.03266916424036026,
0.021478848531842232,
-0.08732733875513077,
0.05207529291510582,
0.06731406599283218,
0.009459168650209904,
0.018460189923644066,
0.008631039410829544,
0.037475328892469406,
-0.07472821325063705,
0.07032401114702225,
-0.0792... | 288 |
amounts each of which is the total of all amounts that were paid or became payable by the trust to a beneficiary of the trust in respect of the interest under the trust before a calendar month that ends in the year except to the extent that the amount is in the income for a taxation year because of subsection amount fr... | [
0.007065857294946909,
0.01619228906929493,
0.023869242519140244,
-0.015741409733891487,
-0.055450279265642166,
0.00437485845759511,
0.08944826573133469,
-0.022596450522542,
0.04961487278342247,
0.041745297610759735,
0.016877351328730583,
-0.08992842584848404,
0.009305301122367382,
-0.02778... | 289 |
in real property or a real right in immovables in Canada or an interest in or for civil law a right in timber resource properties and timber limits in Canada and in respect of which the corporation or trust files a return under this Part in accordance with subsection in respect of the year exceeds average of all amount... | [
-0.047017902135849,
-0.003131348639726639,
-0.031702157109975815,
0.043247755616903305,
-0.06051589921116829,
0.0029341683257371187,
0.07030338048934937,
-0.01729729026556015,
0.04620598256587982,
0.040466006845235825,
0.07565166801214218,
-0.013501472771167755,
0.012719584628939629,
-0.01... | 290 |
capitaux outstanding debts to specified of a corporation or trust at any particular time in a taxation year means total of all amounts each of which is an amount outstanding at that time as or on account of a debt or other obligation to pay an amount was payable by the corporation or trust to a person who was at any ti... | [
-0.03344317898154259,
-0.019711164757609367,
0.018721170723438263,
-0.016767021268606186,
0.024597972631454468,
-0.01090583298355341,
0.08742991834878922,
0.015901418402791023,
0.006499824114143848,
-0.02080623246729374,
0.0787283182144165,
-0.030248310416936874,
0.08945529162883759,
-0.04... | 291 |
as defined by regulation or authorized foreign bank if the bank uses or holds the obligation at the particular time in its Canadian banking business or is a debt obligation described in subparagraph of the description of A in paragraph 17 to the extent that the proceeds of the debt obligation can reasonably be consider... | [
0.015331278555095196,
-0.020758433267474174,
-0.056825846433639526,
-0.055467963218688965,
-0.040188513696193695,
-0.023147927597165108,
0.11808957159519196,
-0.012205514125525951,
0.05743599683046341,
-0.024072779342532158,
0.005754460114985704,
-0.03131671994924545,
0.016987405717372894,
... | 292 |
is a specified beneficiary of a trust the particular person or a person with whom the particular person does not deal at length has at that time a right under a contract in equity or otherwise either immediately or in the future and either absolutely or contingently to or to acquire an interest as a beneficiary under a... | [
-0.03916652500629425,
-0.0016925039235502481,
-0.069329634308815,
-0.047779761254787445,
-0.0667230561375618,
0.04536190629005432,
0.1010928824543953,
-0.0013097614282742143,
0.10027753561735153,
0.018946565687656403,
0.05608626827597618,
0.03596442937850952,
0.019202696159482002,
0.014329... | 293 |
bankruptcy or permanent disability of an individual and the amount of income or capital of the trust that the particular person or a person with whom the particular person does not deal at length may receive as a beneficiary of the trust depends on the exercise by any person of or the failure by any person to exercise ... | [
-0.006123372353613377,
0.02343663200736046,
-0.07756979018449783,
0.001950794248841703,
-0.08410418778657913,
0.04301055148243904,
0.10003158450126648,
0.01608118787407875,
0.02968832664191723,
-0.060691822320222855,
0.09790283441543579,
-0.008621505461633205,
0.05902764946222305,
-0.03078... | 294 |
property unless it is established by the taxpayer that all of the proceeds of costs if received or that would be received from exercising the right must first be applied to reduce an amount described in subparagraph or specified shareholderof a corporation at any time means a person who at that time either alone or tog... | [
0.010584156028926373,
0.026676593348383904,
0.040313079953193665,
-0.0622192919254303,
-0.10947386175394058,
0.0632602721452713,
0.12309093028306961,
-0.0042799427174031734,
0.04689335823059082,
0.05922997370362282,
0.04941457882523537,
-0.032664477825164795,
-0.022777626290917397,
-0.0088... | 295 |
in a corporation or to control the voting rights of shares in a corporation or cause a corporation to redeem acquire or cancel any of its shares than shares held by the particular person or a person with whom the particular person is not dealing at the particular person or the person with whom the particular person is ... | [
-0.05135283246636391,
-0.016145240515470505,
0.009791936725378036,
-0.0372016578912735,
-0.1091890037059784,
0.11315212398767471,
0.10901913791894913,
-0.020394770428538322,
0.04541647061705589,
-0.004318364430218935,
0.11675082892179489,
0.03268549218773842,
0.049065593630075455,
-0.04897... | 296 |
or a specified beneficiary of a trust at any time was in effect at that time an agreement or arrangement under which on the satisfaction of a condition or the occurrence of an event that it is reasonable to expect will be satisfied or will occur the particular person will cease to be a specified shareholder of the corp... | [
-0.015673557296395302,
-0.0052376482635736465,
-0.030193623155355453,
-0.012624094262719154,
-0.05735021457076073,
0.05716536566615105,
0.13056547939777374,
-0.01752144657075405,
0.08506427705287933,
0.008239173330366611,
0.04272657632827759,
-0.06313399225473404,
0.02985716611146927,
-0.0... | 297 |
of subparagraph of the definitionequity amountin subsection a property is partly used or held by a taxpayer in a taxation year in the course of carrying on business in Canada the cost of the property to the taxpayer is deemed for the year to be equal to the same proportion of the cost to the taxpayer of the property wi... | [
-0.019736358895897865,
-0.009405156597495079,
0.044129736721515656,
-0.03618917614221573,
-0.0768463984131813,
0.004254553932696581,
0.03264209255576134,
0.03603652864694595,
0.07590410113334656,
-0.007206439971923828,
-0.0036385238636285067,
-0.07540157437324524,
0.04450811818242073,
0.01... | 298 |
business in Canada the corporation or trust is deemed to use or hold the property in the course of carrying on business in Canada to the extent the partnership uses or holds the property in the course of carrying on business in Canada for the fiscal period of the partnership that includes that time Marginal trust incom... | [
-0.00954361166805029,
-0.02375255897641182,
0.03217063099145889,
-0.04119576886296272,
-0.09152092039585114,
0.037130631506443024,
0.07498376071453094,
-0.012696588411927223,
0.05391031503677368,
0.0011219836305826902,
0.01405689213424921,
-0.00985798705369234,
0.029680682346224785,
-0.012... | 299 |
Subsets and Splits
No community queries yet
The top public SQL queries from the community will appear here once available.