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PRINCIPAL ISSUES: determining the child care component of fees charged by a private school POSITION: question of fact, no % guidelines, but amounts paid for after& before school care will ordinarily qualify as well as the actual per student cost of lunchtime supervision, with respect to kindergarten, no amount of the fees for the educational program qualify even if the program offered is full day rather than half day but if a separate child care program is provided to ensure full day supervision, the amount paid for the separate child care program will qualify REASONS: 63(3) def'n of child care specifically excludes education costs and board 962579 XXXXXXXXXX A. ...

16 November 1995 Income Tax Severed Letter 9529036- Meaning of “readily available” Unedited CRA Tags 118.2(4), 118.2(2)(g) $$$ 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. ...

POSITION: Received by virtue of employment & taxable under 7(1.1) and 7(1)(a). ...

David Duff Income Tax Rulings & Interpretations Directorate May 26, 1998 980811-8 Janice L. ...

Oulton Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

As stated in paragraph 1 of IT-85R2, in order to qualify as a Health & Welfare Trust, the benefit programs funded through the trust must be restricted to one or more of the following plans: a) a private health services plan, b) a group term life insurance policy, or c) a group sickness or accident insurance plan. ...

The issued common shares and voting special shares of Opco are owned in such a manner as to give the shareholder the following percentage of votes: SHAREHOLDER % OF VOTE Can-Res B 19.74 Holdco 49.35 Non-Resco 30.91----- 100.00 Can-Res B is an individual resident in Canada, Holdco is a taxable Canadian corporation and Non-Resco is a corporation resident in the United States. 3. ...

11 May 1990 Income Tax Severed Letter RRRR390 F- Frais de déplacement Unedited CRA Tags 6(1)(b), 8(1)(h), 8(1)(j), 9(1)(h) DATE May 11, 1990 TO FROM A BUREAU PRINCIPAL DE BUREAU PRINCIPAL DE SHERBROOKE Direction des décisions Vicki Plant ' l'attention de D. ...

Boehmer, dated July 16, 1986, includes the following comments: “... the negative ACB of a partnership interest does not simply disappear on an amalgamation of the corporate partner. ...

Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate c. c. ...