30 June 2016 External T.I. 2015-0583561E5 F - Déduction pour gain en capital - contamination -- translation

Principal Issues: Are funds accumulated in AgrInvest and Agri-Québec accounts eligible properties for the definition "share of the capital stock...

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8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules -- translation

Principal Issues: Will subsection 74.4(2) apply in the scenarios described?

Position: No in the first scenario. Probably in the second scenario....

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8 December 2015 External T.I. 2015-0616321E5 F - CEE - Severance pay -- translation

Principal Issues: 1. Whether a severance payment to an employee who performed services on exploration projects would be part of the Canadian...

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8 June 2015 External T.I. 2014-0529851E5 F - Frais payés à une maison de santé ou de repos -- translation

Principal Issues: Several questions regarding the medical expense tax credit.

Position: See document.

Reasons: See document.

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13 May 2016 External T.I. 2016-0635601E5 F - Dépenses de commandite -- translation

Principal Issues: What is the tax treatment of some sponsorship expenses made to a golf club?

Position: None. General comments.

Reasons: Question...

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27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB -- translation

Principal Issues: 1. Whether subparagraph 53(2)(c)(v) would apply to the loans in the situation described in the letter 2. Whether the limited...

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26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu -- translation

Principal Issues:

1) Do the taxpayer's activities qualify as a source of income?

2) If the taxpayer is carrying on a business, are the allowable...

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7 December 2015 External T.I. 2015-0585171E5 F - 7(1)(b) benefit and 110(1.1) election -- translation

Principal Issues: Prior to the sale of the shares of a corporation to an arm’s length purchaser, in a situation where paragraph 7(1)(b) applies,...

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28 January 2016 External T.I. 2015-0617771E5 F - Bump calculation -- translation

Principal Issues: Amounts to be included in 88(1)(d)(i)(B) - deferred income taxes

Position: Not to be included

Reasons: No legal obligation to...

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