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19 May 1995 External T.I. 9423885 F- CRITERES \ CONTROLE DE FAIT Unedited CRA Tags 256(5.1) 256(1)b) 256(3) 256(6) 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. ... A détient 70 % des actions ordinaires de la société X, l'autre 30 % est détenu en parts égales par trois de ses fils. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1) Unedited CRA Tags 250(1)(a) ART IV and XV REG 105 110(1)(f)(i) 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. ... We are not able to find any references in the case of R & L Food Distributors Ltd. 1 ("R & L") described in your letter that a "day" refers to each 24 hour period. ... Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Policy and Legislation Branch 1 R & L Food Distributors Ltd. v. ...

14 November 2007 External T.I. 2007-0255831E5- Medical expenses,travel & lodging,heart transplant Unedited CRA Tags 118.2(2)(g) 118.2(2)(h) 118.2(2)(l.1) Principal Issues: Patient & spouse travelled 400 km for heart transplant; rented basic studio condo near hospital for 3 mths. Asked whether vehicle, food & lodging expenses qualify as a medical expenses and whether flat per km and per meal rates can be used without receipts. ...

11 August 2003 External T.I. 2002-0176465- QFP USED BY INLAWS & DEATH OF SPOUSE Also released under document number 2002-01764650. ... You referred to the situations in documents # 2000-0027385 (the "First Document") and # 2000-0052385 (the "Second Document") and asked for clarifications regarding the farming revenue and use tests in the definition of "qualified farm property" ("QFP") in subsection 110.6(1) of the Income Tax Act (the "Act"). ...

26 May 2010 External T.I. 2009-0342121E5- rooftop solar panels & class 43.2 Principal Issues: 1.will rooftop solar panels & equip qualify for inclusion in class 43.2 under various scenarios subject to the specified energy rules limiting CCA. 2.will claiming cca jeopardize the principal residence exemption? Position: 1.provided expenses incurred for the purpose of producing income & other conditions of the class are met; 2. the principal residence claim will not be jeopardized provided no cca claim is made on the building itself & the earning of income is ancillary to the residence use. Reasons: 1. 1102, 1100(25); 1100; 2.45(2) & IT120-r6 XXXXXXXXXX 2009-034212 Lena Holloway May 26, 2010 Dear XXXXXXXXXX: Re: Technical Interpretation Request regarding Capital Cost Allowance of Solar Panels This is in response to your facsimile correspondence of September 24, 2009 requesting our views as to the income tax treatment of the purchase of solar photovoltaic systems under various hypothetical scenarios. ...

16 November 2020 External T.I. 2020-0864141E5- TI – Tax Treatment of Loan Forgiveness under CEBA Unedited CRA Tags 12(1)(x); 12(2.2); 80 * Principal Issues: What is the tax treatment of forgiveable portion of a loan granted under the CEBA program? ...

5 December 2005 External T.I. 2005-0155331E5- XXXXXXXXXX 2006 Meeting- Q & A's Unedited CRA Tags 18(4) 95(6) Principal Issues: Questions & Answers provided by Wayne Adams at 2006 XXXXXXXXXX Meeting Limited partnerships and thin capitalization Various questions re 95(6) Reverse hybrids and treaty Position: See body of memo Reasons: See body of memo On October 24, 2006, Wayne Adams, Director General of the Income Tax Rulings Directorate, Canada Revenue Agency, attended the XXXXXXXXXX meeting and responded to the following questions: 1. ... The judgment contained the following relevant passage: ".. I am not prepared to say that because a U.S. tax saving that is greater than the Canadian tax saving is envisaged or achieved by a Canadian tax avoidance scheme this in itself takes the transaction outside the ambit of section 245. ...

15 June 1998 External T.I. 9706295- AFFILIATED PERSONS & ESTATE OF DECEASED Unedited CRA Tags 40(3.6) 164(6) 112(3.2) 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. ... Basically: – two individuals are considered to be affiliated only where they are spouses of one another; – Corporations are affiliated to three groups of persons: 1. the person who controls the corporation; 2. members of an affiliated group of persons who control the corporation where an affiliated group is a group of persons each member of which is affiliated with every other member; and lastly the spouses of persons of either of the first two categories. ...

None of the OwnerCos has a permanent establishment in Canada as defined under Article V of the Canada-US Tax Convention (the “US Treaty”) or Article 5 of the Canada – UK Tax Convention (the “UK Treaty”). 6. ... Given the above analysis, it is our view that Fee #2 is a “royalty” as it qualifies as “payments … for the use of, or the right to use, any … information concerning industrial, commercial or scientific experience…” as defined under paragraph 4 of Article XII of the US Treaty. ... As discussed above, we have concluded that Fee #2 paid by CanCo to OwnerCo is for “the use of, or the right to use, … any information concerning industrial, commercial, or scientific experience…”. ...

24 August 1998 External T.I. 9805845- FARMERS & TIMBER Unedited CRA Tags 110.6(1) 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. ... Do they answers to 1 & 2 change if the property was transferred to the taxpayers son in 1985? ... All of the comments in 1 & 2 would apply to the son. 4. It depends. 5. ...