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16 January 2017 Internal T.I. 2016-0651411I7- Reassessment period – transfer pricing Unedited CRA Tags ITA: 152(4)(b)(iii); 152(4.01)(b)(iii); 247(2); 124(4); ITR: 402(3) Principal Issues: Whether subparagraph 152(4)(b)(iii) of the Act allows the Minister to issue an assessment, reassessment or additional assessment of tax under Part I beyond the normal reassessment period (i) to reattribute taxable income earned in a province with respect to a sale of goods to a non-arm’s length non-resident person, (ii) to increase gross revenue attributable to a province that results from a transfer pricing adjustment. ... Ouimet, CPA, CA Attention: John Parker and Dan O’Neil 2016-065141 Reassessment period – transfer pricing We are writing in reply to your request of June 6, 2016, regarding the extended reassessment period under subparagraph 152(4)(b)(iii) of the Income Tax Act (the “Act”). ...

15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares Unedited CRA Tags 39(2) Principal Issues: Whether our position announced at the 1999 TEI Conference and the 2000 CTF Conference regarding foreign exchange losses to the issuer corporation on redemption of its shares is still our position? ... MacMillan Bloedel, 99 DTC 5446 (FCA) January 15, 2007 Emidio De Angelis HEADQUARTERS Acting Banking Industry Specialist Income Tax Rulings Technical Applications & Valuations Division Directorate Montreal TSO S.E. ... Yours truly, Olli Laurikainen, Manager For Director International & Trusts Division Income Tax Rulings Directorate ...

19 September 1991 Internal T.I. 91M09119 F- M & P Tax Credits in Light of the Halliburton and Nowsco Decisions Unedited CRA Tags 125.1 Question 46 What are RCT guidelines for assessment of M&P tax credits in light of the Halliburton and Nowsco decisions? ... BowenCCM # 912407 ...

9 December 1991 Internal T.I. 9122907 F- DSLP for Teachers — Calculation of Six Months Unedited CRA Tags 6801(a) 7-912290 24(1) Re:  Deferred Salary Leave Plan We are writing in reply to your letter of June 7, 1991, to the Kitchener District Taxation Office which was forwarded to us on August 1, 1991.  ... Source Deductions  —  Rulings Kitchener District Office ...

21 November 1994 Internal T.I. 9418117- TUITION & EDUCATION T. C. ... Principal Issues: whether tuition tax credit & education tax credit are available in respect of a university that is NOT designated under the Canada Student Loans program Position TAKEN: yes for both credits Reasons FOR POSITION TAKEN:-tuition tax credit-position stated in IT-516R-education tax credit- November 21, 1994 XXXXXXXXXX DISTRICT OFFICE Rulings Directorate XXXXXXXXXX A. ... While it is unlikely that subsection 118.6(1) of the Act was intended to deny a full time university student an education tax credit because of the lack of designation by the provincial authorities, a strict interpretation of the definition of "designated educational institution" in subsection 118.6(1) would suggest that a university or college which is not "... designated by the Lieutenant Governor in Council of a province as a specified educational institution under the Canada Student Loans Act, designated by an appropriate authority under the Canada Student Financial Assistance Act, or designated by the Minister of Higher Education and Science of the Province of Quebec for the purposes of An Act respecting financial assistance for students of the Province of Quebec... ...

30 June 1995 Internal T.I. 9514457- special purpose trust & taxable benefit from a trust Unedited CRA Tags 105(1) 149(1)(l) 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. ... Would payments made to the parent or guardian of a minor for trust approved expenses (for health, welfare, security & education) be taxable to the parent/guardian under 105(1)? ... Depending on the nature of the governing document, & if not set up to benefit public at large, it would not qualify as either a charity or NPO. ...

23 January 2013 Internal T.I. 2012-0465081I7- Subsection 107(2) – a disposition by a NR Trust CRA Tags 107(2) 116 248(1) "disposition" Principal Issues: Does paragraph 107(2)(a) change the timing of the disposition for the purposes of section 116? ... Subsection 107(2) states: (2) Distribution by personal trust – Subject to subsections (2.001), (2.002) and (4) and (5), if at any time a property of a personal trust or a prescribed trust is distributed (otherwise than as a SIFT trust wind-up event) by the trust to a taxpayer who was a beneficiary under the trust and there is a resulting disposition of all or any part of the taxpayer's capital interest in the trust, (a) the trust shall be deemed to have disposed of the property for proceeds of disposition equal to its cost amount to the trust immediately before that time; (b) subject to subsection (2.2), the taxpayer is deemed to have acquired the property at a cost equal to the total of its cost amount to the trust immediately before that time and the specified percentage of the amount, if any by which… You request our views on whether paragraph 107(2)(a) deems a disposition of the property to occur immediately before the actual distribution from the non-resident trust to the beneficiary. ... The phrase "immediately before that time" as used in paragraph 107(2)(a) of the Act, qualifies only the words "... its cost amount to the trust... ...

27 February 1995 Internal T.I. 9426687- PREJUDGEMENT INTEREST ON AWARD FOR WAGES & REINSTATEMENT Unedited CRA Tags 6(3) 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. ... Where an individual is reinstated, there is no loss of employment & thus any amount awarded cannot be considered as damages from wrongful dismissal February 27, 1995 Shawinigan-Sud Tax Centre Head Office T1 Client Services Rulings Directorate A. ...

17 February 2000 Internal T.I. 2000-0003357- H & W TRUST-DEDUCTION FOR ASO FEES Unedited CRA Tags 9(1) 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. ... John Oulton Manager Business, Property & Employment Income Section Income Tax Rulings Directorate ...

7 April 1997 Internal T.I. 9633857- CLERGY HOUSING-APPOINTMENT, MINISTER & ADMINISTRATION Unedited CRA Tags 8(1)(c) 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. ... Principal Issues: clergymen's residence deduction-whether charity is a religious order, who appointed clergyman to his position, meaning of the terms minister and administration Position: charity not a religious order, question of fact as to who appointed minister to administrative post, the term minister refers to spiritual leader of a religious denomination who performs all the activities including pastoral care and priestly functions, normally associated with the term, administrative service can be distinguised from groundkeeping and accounting in that the latter are specific tasks done at the direction of the administrator Reasons: 8(1)(c) status test involves issue of what is a regular minister function test required determination of whether charity is a religious order, who appointed the minister to his position as well as whether accounting & groundkeeping constituted administrative service April 7, 1997 Kitchener Tax Services Office Headquarters Business Audit A. ... Oulton Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c.: Deanna Dubé, Individual Returns & Payment Processing Directorate ...