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1 June 1990 Internal T.I. 74847 F- Oil & Gas Steering Committee Unedited CRA Tags n/a   June 1, 1990 Special Audits Division Resource Industries E.H. ... Gauvreau   957-8953   File No. 7-4847 Subject: Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ...

13 October 2004 Internal T.I. 2004-0060441I7- Hedging Gains / Losses of Partnership Unedited CRA Tags 20(1)(v.1) Reg 1206(3) Reg 1210(3) Principal Issues: Whether gains / losses realized by a partnership from a hedging activity may qualify for inclusion in the determination of the adjusted resource profits of a member of the partnership. Position: Yes, provided the hedging relates to qualifying production of the partnership such that the gains / losses would be included in the adjusted resource profits of the partnership but only the extent of the members share of such profits. ... Cameron Christine Savage (613) 347-1361 Co-ordinator, Resource Industries Attention: Zul Ladak 2004-006044 Hedging Gains / Losses of Partnership We are writing in response to your query regarding our memorandum dated December 9, 2003, wherein we provided comments in regard to certain Oil & Gas Audit Issue Sheets (our file 2003-00297). ...

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 ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS Unedited CRA Tags 149(10) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... SUMMARY FILE # 933101 Principal Issues: Whether a corporation going from non-taxable to taxable status & therefore subject to 149(10) can claim a terminal loss Position TAKEN: Yes. ... Under paragraph 149(10)(b), such a corporation is deemed to have disposed of all its property, except Canadian or foreign resource property, immediately before the time that is immediately before the change in status, and reacquired the same property at fair market value. ...

21 November 1994 Internal T.I. 9418117- TUITION & EDUCATION T. C. ... Principal Issues: whether tuition tax credit & education tax credit are available in respect of a university that is NOT designated under the Canada Student Loans program Position TAKEN: yes for both credits Reasons FOR POSITION TAKEN:-tuition tax credit-position stated in IT-516R-education tax credit- November 21, 1994 XXXXXXXXXX DISTRICT OFFICE Rulings Directorate XXXXXXXXXX A. ... He told you that a student had been denied the tuition tax credit because XXXXXXXXXX was not listed as a specified educational institution under the Canada Student Loans Act nor was it designated by the Ministry of Human Resources to be an educational institution offering courses that furnish a person with skills for, or improve a person's skills in, an occupation. ...

17 December 1996 Internal T.I. 9625727- REMARRIAGE CLAUSE & DEF'N OF SPOUSAL TRUST Unedited CRA Tags 70(6) 248(9.1) 104(4) 70(9) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Murphy A/Section Chief Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ENDNOTES 1. 94 DTC 1100. 2. 83 DTC 5365. ... Pratte, J., (dissenting in part) said, at page 5374: (...) when did the estate become indefeasibly vested in Mrs. ...

September 8, 1994 XXXXXXXXXX District Office Head Office Audit Adjustments & Enquiry Rulings Directorate C. ... In that case, the taxpayer and his wife had, from the time of their arrival in Canada, worked and pooled all of their resources, assets and income. ... Feder's long history of pooling their resources and sharing property equally, the profit on the land belonged equally to each of them. ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1) Unedited CRA Tags 15(1) 56(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... February 22, 2002 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Tax Services Office Reorganizations and Tax Avoidance Section Resources Division Michael Cooke (613) 957-2126 2001-010186 XXXXXXXXXX We are writing in response to your memorandum dated September 14, 2001, wherein you requested our views concerning the application of subsections 15(1) and 56(2) of the Income Tax Act (the "Act") where a corporation advances funds to another corporation at the direction of the controlling shareholder. ... The severed copy will be sent to you for delivery to the client. for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ENDNOTES 1 On XXXXXXXXXX, Bco borrowed $XXXXXXXXXX under a credit facility it had with the XXXXXXXXXX (the "XXXXXXXXXX Loan"). ...

18 September 2009 Internal T.I. 2009-0318451I7- Language Training- Tuition & Education Tax Credit Unedited CRA Tags 118.5; 118.6 Principal Issues: Is second language training (French or English) at HRSDC certified educational institutions eligible for the tuition tax credit? ... Burnley (613) 957-2100 Attention: Chris Ibbitson 2009-031845 Language Training and Tuition and Education Tax Credits This is in response to your memorandum of April 20, 2009, asking us to review whether tuition paid for English or French second-language training taken at institutions certified by the Minister of Human Resources and Skills Development Canada ("HRSDC") should qualify for the tuition tax credit described in section 118.5 of the Income Tax Act (the "Act"). ...

25 February 2002 Internal T.I. 2002-0118117- PART 1.3- ADVANCES & HOLDBACKS Unedited CRA Tags 181.2(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... In our view, the amounts received by XXXXXXXXXX in respect of its sales of gift certificates, the customer credit balances, the customer deposits and the prepaid cards are all advances within the meaning of 181.2(3)(b) because:- the payments were made in return for the agreement of XXXXXXXXXX to provide goods or services in the future (XXXXXXXXXX);- the payments were made in advance for the eventual performance of the resulting reciprocal obligation, the amount of money the payments represent was available to the corporation which received it, and the payments were an integral part of the financial resources available to XXXXXXXXXX (Oerlikon Aérospatiale Inc. v. ...