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Technical Interpretation - External

19 February 2003 External T.I. 2002-0168355 - FOREIGN PENSION RECEIPTS

Income Tax Convention (the " Convention") applies to exclude the amount. ...
Technical Interpretation - External

17 February 2003 External T.I. 2003-0000605 - CHARITABLE GIFT ANNUITIES

Since this amount does not exceed 80% of the amount paid to the charity, the charity may issue a tax receipt for an eligible amount of $ 47,700 ($100,000 minus $52,300). ...
Technical Interpretation - External

7 February 2003 External T.I. 2002-012676A - Attribution of NPI Royalty Income

In Income Tax Technical News No. 10, dated July 11, 1997, it is stated that: Revenue Canada has traditionally taken the view that a net profits interest (NPI) would constitute a CRP where it entitled the holder to share in the net proceeds from the production and sale by the grantor of the NPI of oil or gas (footnote 1), or the output from a mineral resource in Canada. [...] the Department will accept that in situations similar to the above, an NPI can qualify as a CRP where the conditions of the NPI provide that 90% or more of the total payments for each particular year under the NPI will directly relate to the amount or value of the NPI grantor's production during that year from: i) an oil or gas well in Canada; ii) a natural accumulation of petroleum or natural gas in Canada; or iii) a mineral resource in Canada from which the NPI was granted and, in addition, the remaining payments will be connected to the operation of the above resource property from which the NPI was granted (the "90% test"). ...
Technical Interpretation - External

12 February 2003 External T.I. 2002-0167545 - MFT - Units Issued in Series

In summary, if the first series qualified for distribution to the public, any of the following scenarios would enable the trust to qualify: 150 unitholders of 100 units of the first series; 150 unitholders of 25 units of the second series; (150- N) unitholders of 100 units of the first series + N unitholders of 100 units of the second series. ...
Technical Interpretation - External

24 February 2000 External T.I. 1999-0004805 - housing loans

You posed this question: With the introduction of section 80.4(1.1)(b), to the extent evidence clearly exists that " it is reasonable to conclude that...the debt would not have been incurred" were it not for the employee's relocation, notwithstanding the introduction of section 6(23), would the taxable benefit under such arrangements be computed in accordance with the provisions of section 80.4? ...
Technical Interpretation - External

19 September 2000 External T.I. 2000-0024625 - ISSUANCE OF T2200-SCHOOLS

More specifically, you have requested our comments regarding question # 2 on form T2200 regarding whether you normally require the employees to work away from your place of business, or in different places. ...
Technical Interpretation - External

1 March 2001 External T.I. 2000-0047455 - Non-profit Organizations

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"). ...
Technical Interpretation - External

21 September 1998 External T.I. 9822275 - OTHER INCOME - ASSISTANCE TO FISHERS

Our Comments: The taxation of the lump sum cash payments and the mobility payments available under the FRA program have been discussed in an earlier letter to Human Resources Development Canada (“HRDC”) (file # 5-982005). ...
Technical Interpretation - External

10 May 1999 External T.I. 9818125 F - FAMILLES D'ACCUEIL

L'allocation maximum est de XXXXXXXXXX $ par mois. Cette allocation est fournie en tout ou en partie par les parents naturels de l'enfant. ...
Technical Interpretation - External

13 May 1999 External T.I. 9912425 - XXXXXXXXXX STATUS INDIANS EMPLOYEES

Comments were also provided based on the assumption that XXXXXXXXXX % of the store was on reserve and employees worked throughout it. ...

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