Traduction de «Trop-payé à l'égard d'un contrat de rente normal » (Français → Anglais) :

(o) a payment under an annuity contract (other than a payment in respect of an annuity issued in the course of carrying on a life insurance business in a country other than Canada) to the extent of the amount in respect of the interest of the non-resident person in the contract that, if the non-resident person had been resident in Canada throughout the taxation year in which the payment was made,

(4.3) Notwithstanding subsections (4), (4.1) and (5), if the result of an assessment or a decision on an appeal is to change a particular balance of a taxpayer for a particular taxation year, the Minister may, or if the taxpayer so requests in writing, shall, before the later of the expiration of the normal reassessment period in respect of a subsequent taxation year and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year, reassess the tax, interest or penalties payable by the taxpayer, redetermine an amount deemed to have been paid or to ...[+++] have been an overpayment by the taxpayer or modify the amount of a refund or other amount payable to the taxpayer, under this Part in respect of the subsequent taxation year, but only to the extent that the reassessment, redetermination or modification can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year.

In particular, the three energy companies believe they will suffer two types of financial harm if the aid scheme were to be implemented immediately. Firstly, that caused by the, allegedly too high, fixed prices for the obligatory purchase of domestic coal and, secondly, that resulting from the fines they would have to pay if they failed to respect their international contracts for the provision of gas and coal by virtue of “take or pay” clauses in those contracts.

The Commissioner said that the Council was concerned about competitive disadvantages, and this concern is natural, as in some areas the charges are too high, for instance in northern Scandinavia, where the distance not only to the European market but also within the region and within each country is great.