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7 April 1997 Internal T.I. 9633857- CLERGY HOUSING-APPOINTMENT, MINISTER & ADMINISTRATION Unedited CRA Tags 8(1)(c) 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. ... Principal Issues: clergymen's residence deduction-whether charity is a religious order, who appointed clergyman to his position, meaning of the terms minister and administration Position: charity not a religious order, question of fact as to who appointed minister to administrative post, the term minister refers to spiritual leader of a religious denomination who performs all the activities including pastoral care and priestly functions, normally associated with the term, administrative service can be distinguised from groundkeeping and accounting in that the latter are specific tasks done at the direction of the administrator Reasons: 8(1)(c) status test involves issue of what is a regular minister function test required determination of whether charity is a religious order, who appointed the minister to his position as well as whether accounting & groundkeeping constituted administrative service April 7, 1997 Kitchener Tax Services Office Headquarters Business Audit A. ... Oulton Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c.: Deanna Dubé, Individual Returns & Payment Processing Directorate ...

28 June 1994 Internal T.I. 9407347- EQUIV TO MARRIED TAX CREDIT, NON-RES CHILD & DOUBLING OF Unedited CRA Tags 118(1)(b) 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. ... Principal Issues: technical explanation of 1) the reason why one person in a on-going marriage can't claim the equivalent to married tax credit, 2) the basis for the position of allowing the most beneficial personal tax credit in the year of marital change, 3) whether daughter and father can both claim mother & 4) why 118(1)(b)(ii)(A) makes an exception for a non-resident child Position TAKEN: 1) "not entitled to" means "can't have a deduction"-it is other grounds & the scheme of the Act which prevent a taxpayer from taking a credit under (b) when s/he is married & not separated from spouse 2) it is an administrative position only 3) daughter can't claim mother 4) sojourners and non-residents who earn substantially all their income in Canada can claim equivalent to married for child living with him/her outside of Canada. ... You ask whether the phrase "... an individual not entitled to a deduction by reason of paragraph (a)... ...

26 June 1998 Internal T.I. 9813110- INSTALMENT PAYMENTS & TRUST RETURNS Unedited CRA Tags 156(1) 104(23) 150(1) 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. ... References: ss 104(23) and 156(1) & (2) Canadian Income Taxation of Trusts- page 590. ...

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. ... Pratte, J., (dissenting in part) said, at page 5374: (...) when did the estate become indefeasibly vested in Mrs. ...

16 March 2015 Internal T.I. 2013-0479861I7- Section 116 & forfeited deposits on real property CRA Tags 248(4) 248(1) 116 Principal Issues: Whether a forfeited deposit in respect of a cancelled sale of real property in Canada owned by a non-resident is subject to section 116. ... In support of this view, we refer to subparagraphs (b)(i) and (ii) of the definition of "disposition" at subsection 248(1) if the Act, noting that a disposition of any property includes: "(b) any transaction or event by which, (i) where the property is a[n] … agreement of sale or similar property, or interest, or for civil law a right, in it, the property is in whole or in part redeemed, acquired or cancelled, where property is a debt or any other right to receive an amount, the debt or other right is settled or cancelled,". ... For this purpose, we have considered the definition of taxable Canadian property in subsection 248(1), which includes: "a property of the taxpayer that is (a) real or immovable property situated in Canada, (b) property used or held by the taxpayer in, eligible capital property in respect of, or property described in an inventory of, a business carried on in Canada … (f) an option in respect of, or an interest in, or for civil law a right in, a property described in any of paragraphs (a) to (e), whether or not the property exists, …" When examining whether real property or an interest in real property is taxable Canadian property, attention must be paid to subsection 248(4). ...

12 June 2007 Internal T.I. 2007-0236641I7- Deductibility- ETA interest & penalties Unedited CRA Tags 18(1)(t) 67.6 9 7309 Principal Issues: 1. ... June 12, 2007 Owen Newell, CGA HEADQUARTERS Manager Income Tax Rulings General Operations Unit Directorate Excise & GST/HST Rulings Directorate Tim Fitzgerald, CGA 2007-023664 Deductibility of interest and penalties imposed under Part IX of the Excise Tax Act We are replying to your email of May 17, 2007 wherein you have asked for our views regarding the deductibility of interest and penalties imposed under the Excise Tax Act (the "ETA") for the purpose of computing income for tax purposes. ... Renée Shields Section Manager Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

29 August 2006 Internal T.I. 2006-0193111I7- vesting indefeasibly & validity of trust documents Unedited CRA Tags 70(6) Principal Issues: Did shares vest indefeasibly with the surviving spouse with 36 months of death? ... Despite the apparent irregularities in the director's resolution concerning who requested the redemption, we understand that it was the XXXXXXXXXX % of the shares held by the estate for the children and testamentary debts that were redeemed and not the shares that were transferred to the trust for the benefit of the Spouse. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

9 May 1996 Internal T.I. 9608597- PRIOR PERIOD ALIMONY & WORDING OF AGREEMENT Unedited CRA Tags 60(b) 60.1(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. ... Principal Issues: prior period maintenance payments & phraseology required in the agreement or other document Position: agreement must specify that the prior period payments are made pursuant to the agreement but there is no specific wording required Reasons: it is 60.1(2) that requires a reference to the specific provision of the Act May 9, 1996 SURREY TAX CENTRE Headquarters M. ... Humenuk Assistant Director 957-8953 Enquiries & Adjustments Attention: Carla Fraser Client Services Section 960859 Prior Year Maintenance Payments We are replying to your memorandum of February 27, 1996 concerning the type of wording required in a written agreement, decree, order or judgement of a competent tribunal in order for a taxpayer to deduct payments made to his or her spouse or former spouse prior to the date of the agreement, decree, order or judgement. ...

14 July 1994 Internal T.I. 9416726- CHILD CARE EXPENSE DEDUCTION & CTC SUPPLEMENT Unedited CRA Tags 63 122.2 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

9 May 1991 Internal T.I. 910709 F- Ontario Current Cost Allowance and R & D Superableness Unedited CRA Tags 12a and 12b, 12(1)(x) or 37(1)(d), 13(7.1) Dear Sirs: Re:  Ontario Current Cost Allowance and R and D Superableness This is in reply to your letter of March 7, 1991 concerning the Ontario Superableness for Scientific Research and Development SuPerableness and the Ontario Current Cost Adjustment ("OCCA"). ...