2 October 2015 External T.I. 2012-0463801E5 F - Déduction pour gain en capital – permis de pêche -- translation

2 October 2015 T.I. 2012-0463801E5 F - Capital gains deduction - fishing license

Principal Issues: Whether the wording of clause...

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28 July 2015 External T.I. 2015-0585431E5 F - Frais juridiques -- translation

28 July 2015 T.I. 2015-0585431E5 F – Legal Fees-translation

Principal Issues: Are legal fees incurred against a hidden defect lawsuit following...

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10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Boni suite à la signature d'un contrat d'appro -- translation

10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Signing Bonus for supply agreement

Principal Issues: 1) Is the amount received by a...

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11 December 2015 External T.I. 2015-0601561E5 F - Attribution Rules -- translation

Principal Issues: Will subsection 74.4(2) apply to both scenarios presented?

Position: No in the first scenario. May technically apply in the...

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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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