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These are additions to our set of 2,922 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,928 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

Accordingly, the proposed steps contemplated that all the other steps for the winding-up of SubCo would occur on the same day, but the articles of dissolution for SubCo would not be filed until the tax litigation was settled – and similarly for the winding-up of NewCo2 which was to be commenced and largely implemented perhaps one week later. ...

These are additions to our set of 2,966 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,972 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,978 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,999 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,030 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 3,083 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-02-12 11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e) Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(j.6) s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules 2001-02-02 23 October 2000 Internal T.I. 2000-0027477 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance exclusion for replacement employment at an alleged affiliated employer was not applied 2001-01-19 5 January 2001 External T.I. 2000-0010905 F- Valuation- Freeze shares General Concepts- Fair Market Value- Shares requirement to seek consent detracts to retraction detracts from FMV of freeze preferred shares Income Tax Act- Section 86- Subsection 86(1) right to retract freeze preferred shares must not be fettered 4 January 2001 External T.I. 2000-0047605 F- FRAIS DE DIVERTISSEMENT Income Tax Act- Section 67.1- Subsection 67.1(1) attending shows in order to identity artist recruits might be entertainment Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(a) s. 67.1(2)(a) exception unavailable for tickets to shows attended to recruit artists 10 January 2001 External T.I. 2000-0049585 F- DEDUCTIBILITE DES INTERETS Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) annual payment cap on interest until maturity did not preclude deductibility 5 January 2001 Internal T.I. 2000-0053767 F- IT-92R2 Paragraphe 1 Income Tax Act- Section 9- Timing progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) construction holdbacks not receivable until approved for release 2001-01-05 19 December 2000 External T.I. 2000-0035685 F- RPA TRANSFER AU DECES Income Tax Act- Section 147.3- Subsection 147.3(7) deceased member can have had more than one qualifying spouse or partner ...