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13 August 1997 Income Tax Severed Letter 7M1608- Tuition tax credit — private tutoring Unedited CRA Tags 118.5(1)(a) SUMMARY: Tuition tax credit- private tutoring—ITA-118.5(1)(a)—Whether a tuition tax credit is available for private tutoring. ... Educational institutions that are certified by the Minister of Human Resources Development also qualify if the institution provides courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person's skills in, an occupation. ...

24 May 1989 Income Tax Severed Letter 3-2685- [] XXXX John Shaw (613)957-8983 May 24, 1989 Dear XXXX Re:XXXX Advance Income Tax Ruling Requests As discussed during our recent telephone conversation and during our meeting on May 17, 1989, most of the key issues in the above-captioned matter cannot be resolved until we and our advisors with the Department of Justice have had the opportunity to examine the related documentation. ... Yours truly, for Director Bilingual Services and Resource Industries Division Rulings Directorate ...

17 November 1986 Income Tax Severed Letter 7-0958- [] NOV 17 1986 PENTICTON DISTRICT OFFICE P. ... Logging Tax Deduction The Department's position is that business interruption insurance proceeds are received by virtue of the non-operation of a resource business. ...

June 19, 2002 Vancouver Island HEADQUARTERS Tax Services Office Corporate Reorganization and Resources division S. ... The amounts that were required by paragraph 14(1)(b) to be included in computing the Corporation's income in respect of its business for the taxation year ended March 31, 2000 would be determined as follows in the situation described above: = 8/9 x the "excess" = 8/9 x (variable E in the definition of cumulative eligible capital ("CEC") in subsection 14(5) minus (variable A in the definition of CEC + variable B in the definition of CEC) (= 8/9 x (3/4 of the proceeds of disposition of goodwill for the 1996 and 2000 taxation years) minus (3/4 of the eligible capital expenditures made in the 1995 and 1997 taxation years + the amounts previously included in the Corporation's income in the 1996 taxation year under paragraph 14(1)(b)) (= 8/9 x ((3/4 x $400,000)- ((3/4 x $200,000) + $75,000) (= 8/9 x ($300,000- ($150,000 + $75,000) (= 8/9 x $75,000 = $66,667 Consequently, the amount of CDA under paragraph (c.1) of the definition of CDA would be $33,333 (1/2 x $66,666). ... Maurice Bisson, CGA for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ...

Principal Issues: Deductions available on optional returns under 70(2), 104(23)(d) & 150(4) 1. ... An RRSP deduction, like deductions for an ABIL, exploration & development, moving expenses, can only be claimed on the final return. ... Paragraphs 15-18 of IT-125R4, Dispositions of Resource Properties, discuss the deemed dispositions of any resource property held by a taxpayer at the time of death. ...

11 September 2006 Roundtable, 2006-0185642C6- 2006 STEP Questions 7,8,10,11, & 12 Unedited CRA Tags 116 162(7) 233.1 Principal Issues: 7-8: Administrative issues relating to the delays in obtaining a 116 certificate of compliance. 10-12: Administrative issues relating to foreign reporting requirements 2006 STEP Round Table Q7. ... Response Our International Tax Directorate has been working with CRA staff in the tax services offices and the Regional offices to develop a risk-based audit strategy in order to make better use of our resources which should reduce the delays for most requests. ... Because audit resources are allocated to issues with the greatest risk of non-compliance, the foreign reporting information has resulted in improved file selection. ...

20 July 2000 External T.I. 2000-0018755- Capital Cost allowance & Depletion Re Tree... ... Yours truly, John Chan, CA Manager Resource Industries Section Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

5 August 1999 External T.I. 9918405- PART-TIME EDUCATION TAX CREDIT & TUITION Unedited CRA Tags 118.5 118.6 Pleaae note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Our Comments We understand that XXXXXXXXXX is certified by the Minister of Human Resources Development (“HRD") to be an educational institution pursuant to subparagraphs 118.5(1)(a)(ii) and 118.6(1)(a)(ii) of the Act and is not considered "a university, college or other educational institution providing courses at a post-secondary school level" for purposes of subparagraph 118.5(1)(a)(i) of the Act. ... Pursuant to subparagraph 118.6(1)(a)(ii) of the Act a "designated educational institution" means an educational institution in Canada that is "certified by the Minister of Human Resources Development to be an educational institution providing courses,... that furnish a person with skills for, or improve a person's skills in, an occupation". ...

The total of Company X’s costs in respect of the gas is $800 ($100 + $300 + $400). Company X had purchased the gas from Company Y, and Y’s costs in respect of the gas were $600 ($450 + $50 + $100). ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1- ...

The total of Company X’s costs in respect of the gas is $800 ($100 + $300 + $400). Company X had purchased the gas from Company Y, and Y’s costs in respect of the gas were $600 ($450 + $50 + $100). ... Yours truly, for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1- ...