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13 February 1998 Internal T.I. 9731756- Subsection 20(12) & U.S. ... February 13, 1998 Jennifer Gilmour Enquiries & Adjustments David R. ...

28 July 1998 Internal T.I. 9816177- BED & BREAKFAST Unedited CRA Tags 18(12) 248(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. ... Principal Issues: Whether subsection 18(12) applies in situation where two taxpayers operate a bed & breakfast in a house in which they reside? ...

5 June 1998 Internal T.I. 9805726- FUNDING ARRANGEMENTS-TENANTS & CHARITY Unedited CRA Tags 3 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. ... If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...

OF 115(1)(B) & 116 WHERE A NON-RES. GRANTS AN OPTION Unedited CRA Tags 115(1)(b) 116 115(3) 115(1)(b)(i) 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. ... This interpretation is consistent with our interpretation of the expression " d'un droit y afférent" in the French version. 5-940767 XXXXXXXXXX Carole Pronovost (613) 957-8953 Attention: XXXXXXXXXX November 1, 2018 Dear Sirs: Re: Interpretation of paragraph 115(1)(b) and section 116 where a non-resident corporation grants an option to buy Canadian real property to a Canadian corporation We are writing in reply to your request of March 16, 1994, regarding our interpretation of paragraph 115(1)(b) and section 116 where a non-resident corporation grants an option to buy Canadian real property to a Canadian corporation. ...

8 May 1996 Internal T.I. 9608607- LOAN FOR RENOVATIONS NOT EXEMPT & BONA FIDE REPAYMENTS Unedited CRA Tags 15(2.4) 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. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

17 December 1996 Internal T.I. 9633196- AMT ADJ RQRD IN A LOSS YR & YR OF APPLIC OF THAT LOSS Unedited CRA Tags 127.52 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. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS Unedited CRA Tags 181(1) 181(3) 181.2(3) 181.2(4) 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. ... Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch?? ...

24 April 2003 Internal T.I. 2002-0169537- SR & ED- ACQUIRING RIGHTS Also released under document number 2002-01695370. ... Canco 1 has represented that the Software was used as a tool to assist in the development of its technology / product, and that the Software could not directly achieve the goals initially set out and was rendered virtually useless. ...

22 January 2002 Internal T.I. 2001-0105567- FTC & SBD- PATRONAGE DIVIDEND Unedited CRA Tags 125(1) 135(7) 126(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 CCRA. ... Holloway Verification & Enforcement Division (613)- 957-2104 ATTENTION: Patricia Caron 2001-010556 Foreign Tax Credit and Small Business Deduction override This memorandum is in response to your faxed memorandum of October 12, 2001. ...

15 October 2013 Internal T.I. 2013-0501091I7- 152(4.2) – statute-barred T2 CRA Tags 152(4.2) Principal Issues: Did Bill C-48 amend subsection 152(4.2) to permit the CRA to reassess a corporate taxpayer's statute-barred year? ...