reserve

15 April 2003 Internal T.I. 2002-0176687 F - IMPOT DES GRANDES SOCIETES AVANCES -- summary under Paragraph 181.2(3)(c)

Customers of the corporation paid for services in advance, which the corporation showed as a liability on its balance sheet but deducted as a reserve in computing its income pursuant to s. 20(6). In finding that such amounts were not a reserve described in s. 181.2(3)(c), and before finding that they were includible in taxable capital pursuant to s. 181.2(3)(b), the Directorate stated:

28 January 2021 Internal T.I. 2019-0817641I7 - Acquisition of rights to pension surplus -- summary under Actuarial Surplus

A portion of the purchase price paid for the acquisition of a business of the Seller by the Purchaser was allocated to the actuarial surplus in a defined benefit pension plan (the “Plan”) for which the Seller was the sponsor and employer, with

By services, 28 November, 2015

Fèdèration des Caisses Populaires Desjardins, 2000 DTC 1585 (TCC), rev'd on second (statutory contribution) issue 2002 DTC 7413 (FCA) -- summary under Paragraph 18(1)(e)

The employees of the taxpayer earned vacation leave during a reference period running from May 1 to April 30 each year. When they took their vacation leave in the following twelve-month period, they would receive generally 2% of all their earnings during the reference period for each week of leave taken.

By services, 28 November, 2015

Leonard v. The Queen in Right of British Columbia, [1984] 4 WWR 37 (BCCA) -- summary under Section 87

The reference in s. 87(b) to a "reserve" does not include surrendered lands.

It was stated, obiter, with respect to s. 87(a) that a band "is probably exempt from capital gains tax on the sale of absolutely surrendered lands."

reserve

reserve

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