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3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES Unedited CRA Tags 146(8) 20(1)(bb) 146.3(11) 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 admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming new position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming old position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift 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). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP Unedited CRA Tags REG 8502(d) 20(1)(bb) 9 146(8) 146.3(5) 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 admin fees; 2)RRSP & RRIF investment management fees; 3)RPP (money purchase) admin fees and investment management fees. ...

3 October 1996 External T.I. 9631795- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES Unedited CRA Tags 146(8) 9 20(1)(bb) 146(5) 146.3(11) 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 admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming new position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming old position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift to RRSP for section 146 and Part X.1 purposes; and that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

10 October 1996 External T.I. 9633645- RRSP ADMIN & INVESTMENT FEES Unedited CRA Tags 20(1)(bb) 9 146(8) 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 admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift 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). ...

1 October 2003 External T.I. 2003-0012415- Canada-Luxembourg Treaty Art- 13 & 28 Also released under document number 2003-00124150. ... Question If the corporation realized capital gain from the disposition of shares of a Canadian corporation, the value of which was not derived principally from immovable property, could the corporation rely upon paragraph 4(a) of article 13 of the Canada-Luxembourg Tax Convention (the " Convention ") to exempt the capital gain so realized from taxation in Canada? ...

19 March 2001 External T.I. 2001-0063345 F- RS & DE- MANDATAIRE Unedited CRA Tags 37 127(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. ... XXXXXXXXXX 2001-006334 Sylvie Labarre, CA Le 19 mars 2001 Monsieur, Objet: Dépenses de recherche scientifique et de développement expérimental La présente est en réponse à vos lettres du 24 avril 1998 et du 30 novembre 1998 dans lesquelles vous nous demandiez si l'Agence des douanes et du revenu du Canada (ADRC) pouvait agréer XXXXXXXXXX à titre d'organisation agréée visée à la division 37(1)a)(ii)(E) de la Loi de l'impôt sur le revenu (ci-après la " Loi "). ...

22 October 1992 External T.I. 9227665 F- EBP — Wage Loss Replacement Plan and Health and Welfare Unedited CRA Tags 6(1)(f), 6(1)(g)   5-922766 24(1) D. Duff   (613) 957-8953 Attention:  19(1) October 22, 1992 Dear 19(1) This is in response to your letter of September 18, 1992, regarding the revised Sick Leave Trust Agreement ("Plan") of the School District and requesting our opinion as to the type of plan that it is.  ...

17 February 1992 External T.I. 9200145 F- Small Business Corp & QSBC Definition Unedited CRA Tags 110.6(1) qualified small business corporation share, 248(1) Small business corporation.     920014 L. Holloway 24(1)     (613) 957-2104 Attention:  19(1) February 17, 1992 Dear Sirs: Re:  Technical Interpretation S. 248(1)- Small Business Corporation This is in reply to your request for a technical interpretation concerning the definition of a Small Business Corporation as defined in S.248(1) of the Income Tax Act in the following fact situation: Facts 24(1) 24(1) In particular you were inquiring whether we agreed with your interpretation that in this case, as the property is being used principally in an active business, then 100% of the fair market value of the real property (being $24(1)) is used in evaluating the "all or substantially all test" found in the definition of qualified small business corporation share. ...

3 March 2023 External T.I. 2022-0959251E5- Microprocessor knee prosthesis & the METC Unedited CRA Tags 118.2(2)(i) of the Act and 5700(i) of the Regulations Principal Issues: Whether the cost of a microprocessor knee prosthesis (or C-Leg) would be an eligible expense for the purpose of the medical expense tax credit. ... Reasons: The wording in paragraph 118.2(2)(i) which provides for amounts paid “for, or in respect of, an artificial limb […].” ... Information on how to claim the METC is available on the webpage titled “Lines 33099 and 33199 – Eligible medical expenses you can claim on your tax return.” ...

16 November 2015 External T.I. 2015-0595041E5- Mutual Fund Trusts & 108(2)(a)(i) CRA Tags 108(2)(a) 132(6) Principal Issues: Does CRA still consider a redemption schedule more than once annually satisfying 108(2)(a)(i)? ... Yours truly, Phil Kohnen Manager, Trusts Section I Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...