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9 November 2012 External T.I. 2012-0460471E5- T5013 & non-Canadian partnership CRA Tags ITR 805.1 ITR 229(1) ITR 805 Principal Issues: Does a member of a partnership that is not a Canadian partnership have to file a partnership information return (i.e. ...

6 May 2016 External T.I. 2016-0646411E5- Professional corporation & small business deduction CRA Tags 125 Principal Issues: Impact of 2016 Budget on partnership reorganization rulings Position: See Below Reasons: See proposed legislation in 2016 Budget and paragraph 16 of IC70-6R7. ...

7 July 2016 External T.I. 2015-0595481E5- Ontario Corporate Minimum Tax – Forgiven Debt Unedited CRA Tags 56(1), 57(1) of the Taxation Act, 2007 Principal Issues: Whether a forgiven amount is included in adjusted net income for Ontario corporate minimum tax (CMT) purposes. ...

13 October 2011 External T.I. 2010-0369811E5- Payments to Caregiver / Social Assistance Unedited CRA Tags ITA 81(1)(h); 56 (1)(u) Principal Issues: Whether payments received by caregiver under the Persons with Developmental Disabilities Program are excluded from income under paragraph 81(1)(h) of the ITA. ...

10 November 2011 External T.I. 2011-0415841E5- Trade Union & Trust Filing Requirements Unedited CRA Tags s. 149(1)(e), (k), (l); Reg. 204(1) Principal Issues: Whether a trade union or a trust that has been created by the trade union is exempt from filing a T2 Corporation Income Tax Return, a T3 Trust Income Tax and Information Return, and a T1044 Non-Profit Organization Information Return. ...

1 September 2011 External T.I. 2011-0394641E5- Payments to Respite Care Providers & 81(1)(h) Unedited CRA Tags 81(1)(h) Principal Issues: 1. ...

4 January 2011 External T.I. 2008-0289051E5- Section 116 & Treaty Protected Property Unedited CRA Tags 116(5.01) Principal Issues: (1) In a transfer between parties that are not related persons, in order for the property transferred to qualify as "excluded property" pursuant to paragraph 116(6)(i) of the Act, does the notice described in subsection 116(5.02) have to be filed if the property is "treaty-protected property" as that term is defined in subsection 248(1)? ...

12 May 2006 External T.I. 2005-0159581E5- "Approved " Status Unedited CRA Tags 37(1)(a)(ii) 37(7) Principal Issues: The client requested that XXXXXXXXXX. be approved as a not-for profit corporation entitled for third party payments for SR&ED. ...

2 June 2005 External T.I. 2005-0116801E5- Airplane Lease Costs & Withholding Tax Unedited CRA Tags 6(1)(a) 15(1) 212(1)(d)(xi) Principal Issues: Canco leases an airplane from USco for use in the shareholder's business travel. 1. ...

17 June 2005 External T.I. 2005-0134441E5- Labour Association Annulment & Bank Balance Unedited CRA Tags 8(1)(i) 8(5) 149(1)(k) Principal Issues: Whether the payment of the labour association's bank balance after its annulment to its current members would affect its non-taxable status Position: No. ...