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Technical Interpretation - Internal
22 March 2001 Internal T.I. 2000-0049167 - NON RESIDENT INSURER CIF
No Reasons: Please refer to the analysis in the document March 22, 2001 INTERNATIONAL TAX DIRECTORATE HEADQUARTERS Transfer Pricing & Alison Campbell Competent Authority Attention: Tam Nguyen 2000-004916 XXXXXXXXXX Canadian Investment Fund- Unregistered Reinsurance Reserve XXXXXXXXXX Taxation Years (Your File XXXXXXXXXX) This is in reply to your memorandum of September 25, 2000, regarding the XXXXXXXXXX and its Canadian branch, hereinafter referred to as USCo and the Branch, respectively. ...
Technical Interpretation - Internal
4 December 2012 Internal T.I. 2011-0431871I7 - Part XIII and Procurement Fees
In the present case, the phrase "dependent
on
sales of goods" could thus, as argued by counsel for the respondent, include payments which are dependent on the sales of goods by third parties, like the sales by the manufacturers to Hasbro. ...