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Finance committee Since you're talking about corporations, you would probably prefer to say something like “controlled directly or indirectly, in any manner whatever”. What you're talking about really, I think, is a situation in which it is a corporation of the charity. Relationship is defined i
December 8th, 2010Committee meeting
Edward Short
Finance committee No. Correct me if I'm wrong, but I think you're interested in corporations that are controlled by a charity. So you'd be—
December 8th, 2010Committee meeting
Edward Short
Finance committee Yes. In such a case, using the word “related” is not necessarily going to pick that up.
December 8th, 2010Committee meeting
Edward Short
Finance committee In other situations in which we've had to deal with this problem, we've usually made reference to persons dealing non-arm's-length. It could be, for instance, a corporation that's dealing non-arm's-length with a charity. Under definitions in the Income Tax Act, there could be som
December 8th, 2010Committee meeting
Edward Short
Finance committee You're still looking for somebody who's an employee of the charity, though. Factually they're an employee of the charity, but they're being paid by a corporation. Maybe they're trying to do that to try to avoid the rule. I don't know that they do, necessarily, because if legally
December 8th, 2010Committee meeting
Edward Short
Finance committee —or just raise more issues. First, on the words “unless justified”, personally I'm not certain what that means. If I were somebody in the Canada Revenue Agency, for instance, trying to apply that rule, I would be asking myself what kind of precedent I have to tell me when I am j
December 8th, 2010Committee meeting
Edward Short
Finance committee No, I'm an accountant. I work in this area.
December 8th, 2010Committee meeting
Edward Short
Finance committee I'm not sure if I'm going to help in clarifying the issues—
December 8th, 2010Committee meeting
Edward Short