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15 April 2010 Internal T.I. 2009-0348961I7- Foreign Exchange/Gains & Losses Unedited CRA Tags 9 Principal Issues: Are forward contracts on foreign exchange designed to hedge foreign subsidiaries on account of income or capital? ... The purpose of XXXXXXXXXX is described under its XXXXXXXXXX and is stated as follows: "XXXXXXXXXX " SubCanco manages its exposure by entering into forward foreign exchange and option contracts to hedge the effect of exchange rate changes by creating an offsetting position. ... " It would appear from the above quote that the Supreme Court of Canada did reference the purported hedge to a transaction for purposes of establishing a hedge transaction. ...

23 October 1997 Internal T.I. 9705367- DEFERRED REALIZED GAINS & APPROPRIATIONS OF SURPLUS Unedited CRA Tags 181 190 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. ... " Pursuant to paragraph 3260.02 of the CICA Handbook a reserve is defined for accounting purposes to "... be created or increased only by appropriations of retained earnings or other surplus... ... Dukelow published by Carswell defines "reserve" to include " (a) Amounts appropriated from earned surplus at the discretion of management for some purpose other than to meet a liability or contingency known or admitted or a commitment made as at the statement date or a decline in value of an asset that has already occurred; (b) amounts appropriated from earned surplus pursuant to the articles or by-laws of a corporation for some purpose other than to meet a liability or contingency known or admitted or a commitment made as at the statement date or a decline in value of an asset that has already occurred; and (c) amounts appropriated from earned surplus in accordance with the terms of a contract and that can be restored to the earned surplus when the conditions of the contract are fulfilled. ...

25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment Unedited CRA Tags Article 15 of Canada's Income Tax Convention Principal Issues: When interpreting paragraph 2(c) of Article 15 of Canada's income tax conventions, is the term "permanent establishment" to be determined under the treaty between Canada and the employer's country of residence, or between Canada and the employee's country of residence? ... Yours truly, Olli Laurikainen For Director International & Trusts Division Income Tax Rulings Directorate cc: XXXXXXXXXX ENDNOTES 1 We assume that "offshore Canada" means in "Canada", as defined in Article 3 of Canada's income tax treaties. ...

2 April 2007 Internal T.I. 2007-0225221I7- Foreign Spin-off & Foreign Merger Unedited CRA Tags 86.1(1) 87(8) 87(8.1) Principal Issues: 1. ... Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9) CRA Tags 54 248(1) Treaties Article XIII(9) Treaties Article VI(2) Principal Issues: Is the cottage considered part of the land? ...

13 June 2016 Internal T.I. 2016-0629341I7- Split-pension amount – withholding waivers Unedited CRA Tags 153(1), (1.1), (1.3) and (2), 60.03, 180.2 Principal Issues: Does subsection 153(1.3) of the Act preclude the Minister from considering any request to reduce withholding of tax where a taxpayer has made/expects to make a joint election to split pension income pursuant to section 60.03 of the Act? ...

12 July 1994 Internal T.I. 9410697- INTERACTION OF ALIMONY & PERSONAL TAX CREDIT Unedited CRA Tags 118(5) 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. ...

28 April 1994 Internal T.I. 9410246- USES OF RPP SURPLUS & FORFEITURES Unedited CRA Tags REG 8500(1) REG 8300(8) 147.3(8) REG 8506(2)(b.1) REG 8506(2)(f) 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. ...

30 July 2003 Internal T.I. 2003-0024037- ACB OF LAND & BUILDING Also released under document number 2003-00240370. ...

28 September 2001 Internal T.I. 2001-0084607- HALF-YEAR RULE & CCA Unedited CRA Tags 1100(2) 1100(2.2) 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. ...