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Finance committee  I think “roughly annually” is the way it has worked out. As I'm sure you and committee members are aware, we're heavily implicated in the development of the federal budget and all the legislation related to it. For a significant portion of the year, we don't really focus on a lot

February 28th, 2013Committee meeting

Ted Cook

Finance committee  I'll pass that over to Kerry Harnish to speak to restrictive covenants.

February 28th, 2013Committee meeting

Ted Cook

Finance committee  I'll pass that over to Mr. Short, but I think what I was responding to with Mr. Van Kesteren was the notion that some of the rules in here allow for what is generally called split receipting. It's not so much you give something and what's the value of it and it's auctioned off or

February 28th, 2013Committee meeting

Ted Cook

Finance committee  The most common examples are if you attend a charity dinner, you get the dinner. If you go to a charity golf tournament, you get the value of the round of golf. Those are probably the simplest examples—and I'm going to pass it to Mr. Short to correct me.

February 28th, 2013Committee meeting

Ted Cook

Finance committee  Certainly, as Ms. Roach mentioned, on those measures as well, we haven't heard anything negative since the bill was released in October as a notice of ways and means.

February 28th, 2013Committee meeting

Ted Cook

Finance committee  By way of opening response, I think we can talk to the nature of the amendment. But in terms of specific transaction and specific taxpayers and specific charity, whether the CRA may be looking at something or not—

February 28th, 2013Committee meeting

Ted Cook

Finance committee  By way of opening remark, the concept of fair market value is not defined in the act. It is certainly one of the foundational concepts used in the Income Tax Act and it has been subject to quite a bit of jurisprudence. When you're looking at drafting an income tax act, you can e

February 28th, 2013Committee meeting

Ted Cook

Finance committee  With respect to the short-term resident measure I was talking to, in fact it was released by way of comfort letters, so it's relieving to the taxpayer. In fact, we just kind of wedged it into the bill because we actually received a letter from a lawyer representing one of the aff

February 28th, 2013Committee meeting

Ted Cook

Finance committee  Absolutely, to continue sheltering the income going into the future. The existing rules with respect to losses had contemplated largely the situation of, “we already have rules in the act to deal with that but they deal with corporation-corporation transactions not trust-corpora

February 28th, 2013Committee meeting

Ted Cook

Finance committee  I'll pass it to my colleague Grant Nash, who was more involved with the SIFT, but what you're referring to, I believe, is the normal growth guidelines, so when we implemented the SIFT rules, recognizing that SIFTs were in place, there was a certain expectation that they would con

February 28th, 2013Committee meeting

Ted Cook

Finance committee  You're quite right, the film or video production tax credit was at issue before the Senate in Bill C-10 primarily, I understand, with respect to the public policy test that was related to the credit at that time, a proposed a public policy test. I'm going to pass it to Ed Short

February 28th, 2013Committee meeting

Ted Cook

Finance committee  In terms of how this relates to the budget 2010 measure, the actual main measure, if you will, with respect to budget 2010 and taxable Canadian property, has actually been implemented as part of one of the budget implementation acts. With respect to what's in this bill, it's sort

February 28th, 2013Committee meeting

Ted Cook

Finance committee  That's exactly right with respect to that particular change. We were implementing the 2010 measure, and it was brought to our attention that there was this little inconsistency in terms of the operation of the rule.

February 28th, 2013Committee meeting

Ted Cook

Finance committee  It is. The measures you have before you are in terms of the foreign tax credit generator or specified leasing property. Those are the implementation of the budget measures. It's not that those measures have been previously passed, and these are changes to them.

February 28th, 2013Committee meeting

Ted Cook

Finance committee  Now I understand your question. With respect to that, certainly when the SIFT rules were introduced, there was a provision that SIFT trusts and partnerships, if you will, needed to convert out of SIFT form by the end of 2010 or 2011—

February 28th, 2013Committee meeting

Ted Cook