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11 December 1991 External T.I. 9132315 F- Unpaid Amounts & Inventory Unedited CRA Tags 78(1), 78(4) 913231  24(1) Dear Sirs: Re:  Application of Subsection 78(1) of the Income Tax Act (the "Act") to Costs of Goods Sold                    This is in reply to your telephone enquiry (Holloway/19(1)) related to our response to your firm dated October 23, 1991 concerning the application of subsection 78(1) to the costs of construction capitalized to inventory.  ...

8 January 1993 External T.I. 9226755 F- Charitable & Non-Profit Organizations Unedited CRA Tags 118.1(1) total charitable gifts, 118.1(5) total gifts 5-922675 XXXXXXXXXX Dear Sir: RE:  Technical Interpretation- Donations of Trust Fund to Charities This is in reply to your letter dated September 4, 1992, wherein you request a technical interpretation on section 118.1 of the Income Tax Act (the "Act") in a particular fact situation. ...

19 December 1991 External T.I. 9127875 F- Tuition Tax Credit — Non-refundable Application Fee Unedited CRA Tags 118.5(1)(a) 912787 Dear 19(1): We are writing in reply to your letter of October 2, 1991, wherein you  requested our views on the meaning of the word "enrolled" in the context of paragraph 118.5(1)(a) of the Income Tax Act (the Act) as it relates to the following situation: A college situated in Canada, charges an application fee of $400.  ...

19 January 2012 External T.I. 2011-0425891E5- Art 19 Canada-China Treaty & Immigration Unedited CRA Tags Canada-China Treaty Art. 19, SC 1986, c 48, Part III. ... Position: 1 & 2. Questions of fact specific to the individual. Absent evidence to the contrary, applications for permanent residence can be viewed as strong evidence of an intent to go beyond merely visiting Canada and that an individual's presence in Canada is also meant to establish lasting residential ties. Reasons: 1 & 2. Immigration status is informative but not determinative of residency and residency-related issues for tax purposes. ...

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance CRA Tags 70(6) 73(1.01) 73(1.02) Principal Issues: Scenario whereby income or capital from a proposed spousal trust was to be used to pay life insurance premiums on spouse's life- would this disqualify trust from ever being a spousal trust eligible for rollover of property upon creation of the trust Position: Trust would not qualify for the rollover- would not be a "spousal trust" from inception Reasons: We remain of the view that this would result in someone other than the spouse having use of the trust capital or income while the spouse is alive. ...

16 June 2010 External T.I. 2010-0361221E5- Wheelchair & bath cushion as medical expense Unedited CRA Tags 118.2(2)(i) Principal Issues: 1. ...

2 June 2006 External T.I. 2006-0173251E5- Reward Points / Airplane ticket Unedited CRA Tags 118.1 Principal Issues: Whether the donation of an airplane ticket that has been acquired by redeeming reward points qualifies as a gift for the purposes of section 118.1 of the Income Tax Act. ...

25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1) Unedited CRA Tags 125 Principal Issues: Whether the business limit that can be assigned under subsection 125(3.2) is before or after the application of subsection 125(5.1). ...

E9820215- REPORTING & WITHHOLDING- RETIRING ALLOWANCE Unedited CRA Tags 153(1)(c) 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. ...

E9823475- MANAGEMENT FEES & SWAPS 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. ...