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13 May 2002 Internal T.I. 2002-0116807- M & P- COST OF LABOUR Unedited CRA Tags 125.1 5202 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. ... DISCUSSION The relevant portion of the definition of "cost of labour" of a corporation for a taxation year in section 5202 of the Regulations provides as follows: " an amount equal to the aggregate of (a) the salaries and wages paid or payable during the year to all employees of the corporation for services performed during the year, and (b) all other amounts each of which is an amount paid or payable during the year for the performance during the year, by any person other than an employee of the corporation, of functions relating to (i) the management or administration of the corporation, (ii) scientific research and experimental development, or (iii) a service or function that would normally be performed by an employee of the corporation. ...

Health & Welfare Type Trusts Unedited CRA Tags 94 94.1 Principal Issues: 1. are participants "beneficially interested" in the trust? ... The definition of "arm's length transfer" in proposed subsection 94(1) of the Act reads in part as follows: "arm's length transfer", at any time by an entity (referred to in this definition as the "transferor") means a transfer or loan (which transfer or loan is referred to in this definition as the "transfer") of property (other than a restricted property) that is made at that time (referred to in this definition as the "transfer time") by the transferor to a particular entity (referred to in this definition as the "recipient") where (a) it is reasonable to conclude that none of the reasons (determined by reference to all the circumstances including the terms of a trust, an intention, the laws of a country or the existence of an agreement, a memorandum, a letter of wishes or any other arrangement)for the transfer is the acquisition at any time by any entity of an interest as a beneficiary under a non-resident trust; and (b) the transfer [...] (iv) is a transfer (A) in exchange for which, the recipient transfers or loans property (other than a restricted property) to the transferor, or becomes obligated to transfer or loan property (other than a restricted property), and (B) for which it is reasonable to conclude (I) having regard only to the transfer and the exchange that the transferor would have been willing to make the transfer if the transferor dealt at arm's length with the recipient, and (II) that the terms and conditions, and circumstances, under which the transfer was made would have been acceptable to the transferor if the transferor dealt at arm's length with the recipient, [...] ...

11 October 2013 Internal T.I. 2013-0475761I7- Deadline for filing a waiver of tax credit – ORDTC CRA Tags 150(1)(a) & 127(9)(m) of the ITA 43(1) and 38(1) 2 2007 & (3) of the Taxation Act Principal Issues: Can a corporation file a waiver of tax credit under subsection 43(1) of the Taxation Act, 2007 (TA) to waive all or part of its ORDTC after the deadline for the filing of its income tax return for the year? ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act CRA Tags Bankruptcy and Insolvency Act 13 164(2.01) 241(4)(k) 241(5) 128 150(3) Bankruptcy and Insolvency Act 22 Principal Issues: 1. ...

7 January 2011 Internal T.I. 2010-0384911I7- Education & Textbook Tax Credits Unedited CRA Tags 118.6(1), 118.6(2.1) Principal Issues: If an individual received reimbursement from their employer for one of four courses taken at a designated educational institution, can the "program" consist of the remaining three courses that will allow the individual to claim the education and textbook tax credits. ...

4 June 2009 Internal T.I. 2009-0314631I7- Taxation & Insolvency Unedited CRA Tags S. 168(1) Excise Tax Act S. 152(1) Excise Tax Act S. 296(1)(b) Excise Tax Act Principal Issues: Whether an assessment under s. 296(1)(b) of the Excise Tax Act predates the filing of a proposal under the Bankruptcy and Insolvency Act Position: Yes. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94 Unedited CRA Tags 216 118.94 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. ...

13 May 1996 Internal T.I. 9614040- EMPLOYEE INCENTIVES-GIVEAWAYS & LOTTERY SCHEMES Unedited CRA Tags 6(1)(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. ...

24 August 2001 Internal T.I. 2001-0096247- SR & ED- Investment Tax Credit Unedited CRA Tags 251(2)(b) 251(1)(b) 127(9) 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. ...

23 January 2003 Internal T.I. 2003-0183797- Capital Div Account- MFC & MFT Distrib. ...