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Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc XXXXXXXXXX, Income Tax Audit XXXXXXXXXX Tax Services Office ...

Canadian Pipelines & Petroleums Limited [1960] S.C.R. 126). Provided that the mining claims qualify as a "right to explore for minerals in a mineral resource in Canada", it is our view that the shares received by Mr. ...

The Canada Revenue Agency's Interpretation Bulletin IT-346R establishes an administrative position which allows a person who meets the definition of "speculator" at ¶ 6 of the Bulletin to elect to report the income resulting from such transactions, for income tax purposes, as being on account of capital instead of income. ...

As we advised you in XXXXXXXXXX, the CRA has accepted the Federal Court (the "Court") decisions in Signalgene R & D Inc. v. ...

Facts The facts, as we understand them, are as follows: Taxpayer, a Canadian citizen and a resident of Canada for purposes of the Act and the Canada – U.S. ...

29 September 2011 Internal T.I. 2011-0420701I7- Interest on a Taxpayer Requested Adjustment Unedited CRA Tags s. 161(7)(b)(ii) & (iv) Principal Issues: What is the date to be used when calculating interest where Years 1 to 7 were reassessed, resulting in losses being converted to income, and the taxpayer states during the audit that it would be applying losses for the current year to reduce taxable income in one of those reassessed years? ...

For more information regarding the repayment of a salary advance, see “salary overpayments” in chapter 6 of CRA Guide RC4120, Employers’ Guide – Filing the T4 slip and Summary. ...

July 13, 2011 Small & Medium Enterprises Directorate HEADQUARTERS Specialty Audit Section Income Tax Rulings Directorate Attention: Rubin Dressler E. ...

November 8, 2011 Policy & Legislative Research Taxpayer Services and Debt Management Branch Income Tax Rulings Attention: MaryAnn McNulty Directorate Shelley Helmer (613) 957-2118 2011-041753 Exemption for XXXXXXXXXX Retiree Medical Benefits Trust This is in response to your email of August 5, 2011 wherein you inquired whether XXXXXXXXXX Retiree Medical Benefits Trust (the "RMB Trust") qualifies for an exemption from Canadian taxation pursuant to paragraph 2 of Article XXI of the Canada-United States Tax Convention (the "Convention"). ...

MEMORANDUM NOTE DE SERVICE DATE November 22, 2011 TO Kitchener Tax Services Office FROM Income Tax Rulings Directorate À DE Ontario Corporate Tax Division Bonnie Ruttan-Morillo Attention: Helen Zelobowski FILE 2011-041557 DOSSIER SUBJECT: Ontario Manufacturing & Processing ("M&P") Tax Credit and Ontario OBJET: Capital Tax Credit for Manufacturers This is in reply to your email dated July 28, 2011, regarding a corporation's eligibility for the Ontario M&P income tax credit and the Ontario capital tax credit for manufacturers where the corporation's activities consist solely of scientific research and experimental development ("SR&ED"). ...