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The Definition reads as follows: " "eligible apprentice" means an individual who is employed in Canada in a trade prescribed in respect of a province or in respect of Canada, during the first twenty-four months of the individual's apprenticeship contract registered with he province or Canada, as the case maybe, under an apprenticeship program designed to certify or license individuals in the trade;" Quebec- the CCQ In Quebec, apprentices in the construction trades are required to be registered as apprentices with the CCQ. ...

La prime annuelle est de 10 000$ et le capital assuré est de 500 000 $. ...

OUR COMMENTS Interaction of subsection 80.01(3), subsection 80(1) "Forgiven amount" and paragraph 80(2)(k) Subsection 80(1) defines the term "forgiven amount", in part, as follows: " 'forgiven amount' at any time in respect of a commercial obligation issued by a debtor is the amount determined by the formula A- B Where A is the lesser of the amount for which the obligation was issued and the principal amount of the obligation, B is the total of, a) The amount, if any, paid at that time in satisfaction of the principal amount of the obligation,.... ...

As a result, we are of the opinion that US Holdco satisfies paragraph 3 of Article XXIX A (LOB) and can benefit from the reduced rate of Canadian withholding tax in Article X of the Treaty, provided that US Holdco satisfies the conditions in Article X of the Treaty. for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

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

Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In addition to the foregoing, prior to his death, the deceased had invested in a new limited partnership, which raised funds to invest in flow-through shares of various mining and oil & gas resource corporations. ...

Yours truly, Sandy Parnanzone For Director, Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

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

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