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Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Is the income earned by a farmer for the rental of farmland to a third party who enters into FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ...

18 April 2013 External T.I. 2013-0484631E5- Employee Bursary & Education Tax Credit CRA Tags Regulation 200(2) 6(1)(a) 118.5 118.6 Principal Issues: Change in position taken in Document 2012-043551 Position: ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ... Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

1993 External T.I. 9314270 F- Permanent Establishments & Independent Agents (4112-2-5) Unedited CRA Tags Treaty US Article V Corporate Management Tax Conference Canada-U.S. Income Tax Convention: Permanent Establishment & Independent Agent Question 5 Under the Canada-U.S. ...

16 August 1995 External T.I. 9512405- VESSELS- PARTIAL DISPOSITION & 13(16) ELECTION Unedited CRA Tags 13(16) 13(21) 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. ... Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

3 February 1997 External T.I. 9701825- STATUS OF GMBH & CO KG 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: Whether a GmbH & C0 KG is a corporation or a partnership for purposes of the Act. ...

The relevant exclusions are: Paragraph (l) – if the non-resident trust is a foreign affiliate of the taxpayer for purposes of section 233.4 of the Act. ... Paragraph (m) – if the interest in the non-resident trust was not acquired for consideration by the taxpayer, or certain other persons. ... Paragraph (n) – if the trust is described in paragraph (a) or (b) of the definition of “exempt trust” in subsection 233.2(1) of the Act. ...

16 June 2017 External T.I. 2017-0698181E5- New principal residence rules & trusts Unedited CRA Tags 40(6.1); 54 Principal Issues: How do new principal residence rules apply to a Graduated Rate Estate with a non-calendar year-end? ... The October 3, 2016 Notice of Ways and Means Motion proposed amendments to the definition of principal residence in section 54 of the Act limiting the types of trusts that could claim the exemption in years beginning after 2016 and by adding the following after subsection 40(6): (6.1) Principal residence – Property owned at end of 2016 — If a trust owns property at the end of 2016, the trust is not in its first taxation year that begins after 2016 a trust described in subparagraph (c.1)(iii.1) of the definition principal residence in section 54, the trust disposes of the property after 2016, the disposition is the trust's first disposition of the property after 2016 and the trust owns the property, whether jointly with another person or otherwise, continuously from the beginning of 2017 until the disposition, (a) subsection (6) does not apply to the disposition; and (b) the trust's gain determined under paragraph (2)(b) in respect of the disposition is the amount, if any, determined by the formula A + B – C where A is the trust's gain calculated in accordance with paragraph (2)(b) on the assumption that (i) the trust disposed of the property on December 31, 2016 for proceeds of disposition equal to its fair market value on that date, and (ii) paragraph (a) did not apply in respect of the disposition described in subparagraph (i), B is the trust's gain in respect of the disposition calculated in accordance with paragraph (2)(b) on the assumption that (i) the description of B in that paragraph is read without reference to "one plus", and (ii) the trust acquired the property on January 1, 2017 at a cost equal to its proceeds of disposition determined under the description of A, and C is the amount, if any, by which the fair market value described in subparagraph (i) of the description of A exceeds the proceeds of disposition of the property determined without reference to this subsection. ...

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. ... Murphy for Director International and Trusts Division Income Tax Rulings Directorate c.c.: Wendy Coderre Partnerships Information Returns, Capital Gains, Deceased & RCA Specialty Publications Section Client Services Directorate ...

2 November 2015 External T.I. 2015-0594431E5- Ontario Energy & Property Tax Credit Principal Issues: Are land lease payments for a mobile home eligible for determining the Ontario Energy & Property Tax Credit? ... XXXXXXXXXX 2015-059443 George A Robertson, CPA CMA (905) 721-5196 November 2, 2015 Dear XXXXXXXXXX, This is in response to your letter dated June 2, 2015, enquiring whether the land lease cost paid by you can be used in the property tax amount of the calculation of the Ontario Energy & Property Tax Credit (“OEPTC”). ...

19 August 1997 External T.I. 9718445- RRSP INVESTMENT COUNSEL & MANAGEMENT FEES Unedited CRA Tags 18(1)(u) 146(5) 146.3(2)(f) 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: 1)RRSP & RRIF investment counsel fees; 2) RRSP & RRIF investment management fees Position: 1)Confirming position that counsel fees paid inside RRSP or RRIF trust constitute benefit or amount received to annuitant; payment by annuitant not deductible; 2) Confirming position that investment management fees paid by annuitant are considered payment of a premium to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...