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Yours truly, Helen Ferrigan A/Section Manager for Division Director Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

5 December 1990 External T.I. 90M12235 F- Employee Benefit Plans Existing Prior to December 31, 1987 Unedited CRA Tags 125(7) specified investment business, 248(1) small business corporation, 248(4), 249(4), 256   December 5, 1990 S.G. ...

To show the effect where contingent beneficiaries are concerned, we have considered the grandchildren's rights to arise only on the death of a child. 1.      ...

In our view, the Plan would be considered an EBP – except for the portion, if any, of the Plan that is determined to be an RCA. ...

Yours truly, Sandro D’Angelo, CPA, CMA Acting Manager Business Income and Capital Transactions Section Business and Employment Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...

XXXXXXXXXX 2021-088766 Matthew Ross, CPA, CA January 26, 2023 Dear XXXXXXXXXX: Re: Small Business Deduction – Related Corporations We are writing in response to your email of April 3, 2021 in which you requested our views regarding certain aspects of the small business deduction (“SBD”) rules found in section 125 of the Income Tax Act (“the Act”). ...

Nerill Thomas-Wilkinson, CPA, CA Manager Non-Profit Organizations and Indigenous Issues Speciality Tax Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 The Queen v Robertson et al 2012 FCA 94; 2010 TCC 552 Leave to Appeal to the SCC dismissed 2 Ballantyne v The Queen 2012 FCA 95; 2009 TCC 325; 2012-10-25 SCC Docket 34840 – Leave to Appeal Dismissed with Costs 3 Paragraph 86 Robertson ...

Where the conditions of paragraph 8(1)(h) and subsection 8(4) of the Act are met, subsection 8(10) of the Act further requires that Form T2200 – Declaration of conditions of Employment be completed by the employer. ...

26 August 2024 External T.I. 2024-1016421E5- XXXXXXXXXX Disability Supports Payments Unedited CRA Tags 56(1)(u); 56(2); 110(1)(f); Reg. 233(1) & 233(2) Principal Issues: Whether payments made under the XXXXXXXXXX Disability Supports Program to persons with disabilities (PWDs) would be included in the PWD's income. ...