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Generally, in files where the status of XXXXXXXXXX MRPS as equity – as opposed to debt or some other type of instrument- was relevant, Rulings accepted that such MRPS would be treated as equity for purposes of the Act. ...

September 20, 2002 International Policy & Business HEADQUARTERS Management Division Income Tax Rulings Directorate Policy and Publications Unit I S. ...

The Queen, 2009 TCC 293 as follows: “ Cranswick must be read in light of the fact that the trial judge's statement that the payment was not made by reason of any enforceable claim asserted by the shareholders of the Canadian subsidiary results from a specific statement to that effect contained in an agreed statement of facts. ...

C.35: Subsection 55(1) "... [T]he surplus arising from the business of a co-operative... in each fiscal year shall be allocated, credited or paid to the members in proportion to the business done by each member with or through the co-operative... ...

As explained by Ottawa TSO's Appeals Division, the Rep's position after reviewing the calculation in the TSO's schedule is as follows: "XXXXXXXXXX " Our Comments In our view, the amount of net capital losses deducted under paragraph 111(1)(b) in XXXXXXXXXX that is to be taken into account in computing the amount referred to in subparagraph (a)(i) of parameter B in the definition of the AGL in subsection 110.6(1), which amount in turn affects the amount determined for paragraph (b) of the definition of CGL, should be $XXXXXXXXXX (i.e., $XXXXXXXXXX less $XXXXXXXXXX). ...

You estimate that XXXXXXXXXX to XXXXXXXXXX % of aboriginal persons living in XXXXXXXXXX belong to the XXXXXXXXXX. ...

XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

., 4th Floor Isabeau Morrissette Toronto ON M5C 1J7 (514) 283-5259 Attention: Cynthia Rhodes, Group # 443-3-1 2007-022422 Subject: Carrying on business in the United States (US) This is in reply to your various emails regarding the above-mentioned file. ...

Les cotisations établies ne pouvant être modifiées (...), je dois simplement conclure que le montant inclus au revenu et qui représente des intérêts doit effectivement être maintenu comme revenu. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...