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The taxpayer can direct that the funds be used at the Centre for:         A.   ... Of particular concern was the requirement in subsection 37(1)(a) of the Act that;     "... the taxpayer is entitled to exploit the results of such scientific research and experimental development... ... A Payer will be entitled to deduct from its income a contribution made in the year to a University pursuant to clause 37(1)(a)(ii)(B) of the Act, provided that the following conditions are met:          a)  the Payer carries on business in Canada in the taxation year;          b)  the funds are to be used by the University for SR&ED carried on in Canada;          c)  the SR&ED activity carried on by the University is related to the business of the Payer in the year the expenditure is made;          d)  the Payer completes and files Form T661, "Claim for Scientific Research and Experimental Development Expenditures"; and          e)  the Payer is entitled to exploit the results of the SR&ED. ...

7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus Unedited CRA Tags ITR 5902(2), 93(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 5902(2)(a) of the Regulations to the Act This is in reply to your letter wherein you requested clarification of the operation of section 5902 of the Regulations to the Income Tax Act (the "Act") in the following hypothetical circumstances: 1)     A corporation resident in Canada ("Canco") owns 95% of the common shares of a foreign affiliate ("FA1") which in turn owns 100% of the common shares of a second foreign affiliate ("FA2"). ... Both FA1 and FA2 have exempt surplus balances in respect of Canco. 2)     Canco disposes of its shares of FA1 to a third party and elects under subsection 93(1) of the Act to have a portion of the proceeds of disposition deemed to be a dividend received on those shares. ...

15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits Also released under document number 2003-00268270. ... January 15, 2004 ASSESSMENT & COLLECTIONS BRANCH HEADQUARTERS Individual Returns & Payment Processing Income Tax Rulings Directorate Directorate S. ...

16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9 CRA Tags 156 Principal Issues: Whether the CRA will continue with its practice of not assessing interest and penalties where an inter vivos trust does not make instalment payments as required under section 156. ... STEP CRA Roundtable – June 2014 QUESTION 9. Interest and Penalties on Deficient Instalments of Inter Vivos Trusts In response to question 20 at the 2010 STEP Canada National Conference, the CRA noted that under the current administrative policy, the CRA does not assess installment interest and penalties where an inter vivos trust does not make installment payments required under section 156. ...

6 August 1980 Income Tax Severed Letter RRRR15- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

6 August 1980 Income Tax Severed Letter RRRR16- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan Unedited CRA Tags 6(1)(a), 248(1) “private health services plan” Principal Issues: Whether a health spending account established for a sole employee-shareholder can qualify as a private health services plan. ... CALU Roundtable – May 2022 Question 10 – Private Health Services Plans Background An employer can offer its employees a Private Health Services Plan (PHSP) that takes the form of a Health Spending Account (HSA), also known as a cost-plus plan. ...

15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Unedited CRA Tags 85; 261 Principal Issues: Whether the CRA can confirm in which currency amounts reported in form T2057 should be denominated in circumstances where section 85 applies in respect of a property transferred by a transferor that has a tax reporting currency different from that of the transferee. ... The first scenario of example 3 in paragraph 1.69 of the Folio S5-F4-C1 – Income Tax Reporting Currency (Feb. 27, 2019) provides an example of a situation where subsection 261(18) of the Act might be applicable. ...

14 May 1993 Income Tax Severed Letter 9313025 F- Acquisition and Disposition — Property — General Unedited CRA Tags 54(c) 248(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. ...