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27 September 1993 External T.I. 9320515- Congres de l'APFF — Table Ronde?? Unedited CRA Tags 186(1)(b), 152(4), 152(6), 187(3)   TABLE RONDE SUR LA FISCALITÉ FÉDÉRALEAPFF — CONGRES 1993 QUESTION #9 F Ltée obtient un remboursement au titre de dividende suite au paiement d'un dividende sur les actions détenues par sa compagnie-mère, CM. ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST Unedited CRA Tags 18.1 108(2)(a)(i) 18.1(15)(a) 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. ... The Bank will agree to make a payment (the "Swap Termination Payment") to the Trust on or about XXXXXXXXXX (the "Swap Termination Date"), determined approximately by the following formula: [(I1 * (.998125)42)- 1] * Y I0 where: I' = Index at Swap Termination Date 10 = Index at Closing Date Y = Proceeds of Offering less any Early Termination If the amount determined by the foregoing formula is negative, no payment will be made by the Bank and the Trust will not be required to make a payment to the Bank. 9. ... The Bank will be required to pay to the Trust, on an Early Termination, an amount (the "Early Termination Payment") determined approximately by the following formula: [(It * (.998125)t)- 1] * Z I0 where: It = Index at quarter t 10 = Index at Closing Date Z = Early Termination Reduction t = number of quarters since Closing Date If the amount determined by the foregoing formula is negative, the Trust will be required to pay such amount to the Bank (a "Trust Unwind Payment"). ...

La rémunération des employés visés se situe entre XXXXXXXXXX $ à XXXXXXXXXX $. Parmi les XXXXXXXXXX employés touchés, XXXXXXXXXX ont un salaire annuel excédant XXXXXXXXXX $ (en incluant les primes admissibles au calcul de l'indemnité de départ) et quelques-uns ont une rémunération inférieure à XXXXXXXXXX $. ... Par exemple, si l'employé renonce à un montant d'indemnité de XXXXXXXXXX $, le montant assigné à l'employé par la fiducie s'élèvera à XXXXXXXXXX $. ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y) CRA Tags 95(2)(m) 95(2)(y) Principal Issues: For the purposes of applying paragraph 95(2)(a) in determining whether a taxable Canadian corporation that is a member of a partnership has FAPI, does paragraph 95(2)(y) apply to prevent the partnership from having a qualifying interest in a foreign affiliate the shares of which are owned through the partnership? ... XXXXXXXXXX 2011-041591 Yannick Roulier July 12, 2013 Dear XXXXXXXXXX: Re: Foreign affiliate held through a partnership –- paragraphs 95(2)(m) & 95(2)(y) This is further to a letter from XXXXXXXXXX dated July 26, 2011, requesting our comments regarding the application of paragraphs 95(2)(m) and (y) of the Income Tax Act in a situation where a foreign affiliate is held through a partnership. ...

Our Comments In accordance with clauses 37(1)(a)(ii)(A) to (D) of the Act, an entity providing scientific research and experimental development ("SR & ED") funding can qualify for the SR & ED tax incentives by making a payment to any one of the following entities which carry on SR & ED activities in Canada: (A) an approved association; (B) an approved university, college, research institute or other similar institution; (C) a corporation resident in Canada and exempt from tax under paragraph 149(1)(j) of the Act; or (D) a corporation resident in Canada. ... (A) Approved Association In order for any association, whether in existence or proposed to be created, to become an "approved" association, the following requirements must be met: 1. it must have the facilities and personnel capable of carrying out SR & ED; 2. it must carry on only activities that are unquestionably SR & ED; 3. it must satisfy the requirements for non- profit status, such as no personal benefit to members, no control of other associations, satisfactory provisions for distribution of assets upon dissolution, etc.; and 4. the funding of the association must be sufficient to ensure ongoing SR & ED. ... The SR & ED activity may be directly undertaken by or on behalf of the corporation or by an entity described in clause 37(1)(a)(ii)(A) or (B) of the Act; and 5. the amounts to be expended in Canada on SR & ED must not be less than 90% of the corporation's income for the period. ...

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS Unedited CRA Tags 146.01(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 CCRA. ... Principale Question: Est-ce que l'acquisition d'une unité qui est composée d'un bail en propriété et d'un nombre d'actions de la société détenant l'immeuble est considérée comme étant une " habitation admissible" aux fins de l'article 146.01 de la Loi? ... RAISON POUR POSITION ADOPTÉE: Situation particulière de fait pour laquelle nous avons déjà rendu des décisions positives pour les fins de la définition de " résidence principale " à l'article 54 de la Loi. ...

25 May 1992 Income Tax Severed Letter 9212395- Manufacturing and processing profits tax credits — Nowsco and Halliburton court cases Unedited CRA Tags 125.1, 127, Reg. ... SUBJECT: M&P CREDITS/NOWSCO & HALLIBURTON CASES SECTION: 125.1, 127, CLASS 29] ISSUE SHEET Question 30- Manufacturing and Processing Profits Tax Credits (1991 Canadian Tax Foundation Roundtable) Issue The question asked for Revenue Canada's assessing guidelines for M&P credits in light of the Federal Court of Appeal decisions in Nowsco, [[1990] 1 C.T.C. 416] 90 DTC 6312 and Halliburton, [[1990] 1 C.T.C. 427] 90 DTC 6320. ... Tax Conference in September, 1991 and is consistent with the Appeals Decisions # 86-14R and # 90-30, both dated August 17, 1990, pertaining to the Halliburton and Nowsco cases, respectively.... cont... ...

7 December 1991 Income Tax Severed Letter- Disability insurance — application of ITAR-19 Unedited CRA Tags ITAR 19 XXX Disability Insurance- Application of ITAR 19 We are writing with respect to your memorandum of December 5, 1991, and the enquiry from Scarborough D.O., wherein our views were requested as to whether or not the benefits the taxpayer will receive in 24(1) (the company) would be taxable in the taxpayer's hands. Our understanding of the facts in this case is as follows: XXX Our Comments General Comments In order for benefits payable under a plan to be totally exempt from income tax under ITAR 19, all of the following conditions must be fulfilled: • the event that gave rise to the disability payments must have occurred prior to 1974, • the plan must have been established prior to June 19, 1971, and • the plan must not be a changed plan except to the extent permitted under ITAR 19(2). ... Specific Comments From our review of the documentation and explanations set out in the D.O. referral, it is our view that: • the event that gave rise to the taxpayer's disability occurred prior to 1974, as discussed in paragraph 3 of IT-428 and as evidenced by the document dated XXX • the plan was established prior to June 19, 1971, and, • the plan is a changed plan as evidenced by the major revision that became effective on XXX In view of the foregoing, it is our view that the benefits to be received under the plan, will be partially exempt from income tax under ITAR 19(1) as discussed in IT-54 generally and paragraph 21 of IT-428, specifically. ...

10 April 1992 External T.I. 9132345 F- Employed in Canada – Director's Fees Unedited CRA Tags 114, 2(2)   913234 24(1) K.B. ... (ii)     The individual, during the non-residency period in the year, owned a limited partnership unit. ... Subsection 248(1) of the Act defines employed as "... performing the duties of an office or employment". ...

30 March 1988 Income Tax Severed Letter 5-5293- [] Unedited CRA Tags 95(2)(i) Dear Sirs: We are writing in response to your letter dated December 29, 1987 in which you have asked for the Department's views on the application of paragraph 95(2)(i) to the following hypothetical situation. ... Provided there is clear evidence, at the time of the disposition of the excluded property, that arrangenents are being made for the repayment (with due dispatch) of the "related debt", it is our view that the fact that the actual repayment of the debt occurs after the disposition of the excluded property would not, in and by itself, result it the debt not being considered "... related at all times... ". However if it was determined that other factors (such as cash flow problems, or unfavourable prevailing interest or exchange rates) contributed to the delay in repayment, it is likely that the provisions of paragraph 95(2)(i) would not apply on the repayment of the debt. ...