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With respect to the corporation owned by the deceased's parents we are not sufficiently aware of the facts surrounding the outstanding advance of $ XXXXXXXXXX and the estate's failure to repay the amount to the corporation to forcefully offer an opinion. ...

You further indicated that ¶2601 of the book titled "Preparing Your Income Tax Return" written by Arthur Andersen & Co., Chartered Accountants, states that "a business loss from a year of residence may not be applied in a year of non-residence... ...

Where a provincial act applies instead of the PBSA, it will depend on the provisions of that particular act. for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Senécal Appeals & Referrals Division (613)957-9796 Headquarters-Appeals Directorate Attention:Neil Wilson 950508 XXXXXXXXXX This is in reply to your memorandum of February 23, 1995, wherein you request our comments regarding the income tax implications arising out of the following fact situation: XXXXXXXXXX is a United States corporation which is not resident in Canada for the purposes of Part I of the Income Tax Act (the "Act"). ...

Her home is maintained for the use of up to 4 foster children & thus the income is exempt June 7, 1995 VANCOUVER TAX SERVICES HEADQUARTERS Audit Division A. ...

Item # 10(a) of the prescribed form T2200 simply asks the employer whether the employee was required under a contract of employment to use a portion of his or her home. ...

Principal Issues: whether fees paid to a tutor qualify as a medical expense Position TAKEN: no Reasons FOR POSITION TAKEN: cost of tutor not elibigle for tution or medical expense tax credit in certain circumstances, 118.2(2)(e) provides for care & training at a school, institution or other place but using the principle of ejusdem generis, the home of a tutor will not qualify as an "other place" August 10, 1995 Ottawa Tax Services Headquarters Client Assistance Division A. ...

Principal Issues: whether the taxpayer was entitled to a deduction under para 8(1)(c), & more particularly whether the organization which appointed him was a religious order Position TAKEN: no Reasons FOR POSITION TAKEN: question of fact: the organization in question is more a non-profit organization with humanitarian objectives then a religious denomination July 28, 1995 Toronto Centre Tax Services HEADQUARTERS Appeals D. ...

Principal Issues: whether the taxpayer was entitled to a deduction under para 8(1)(c), & more particularly whether the religious organization which appointed him was a religious denomination Position TAKEN:no Reasons FOR POSITION TAKEN: question of fact: the religious organization in question is more XXXXXXXXXX than a religious denomination July 28, 1995 XXXXXXXXXX Tax Services Income Tax Rulings and Office Audit Interpretations Directorate A. ...

Files 920244, 920894, and 921589 contain position which will be superceded by the position contained in this memo and an opinion being issued in file # 950769 At issue is whether or not someone loses their right to designate a property as their principal residence if a property was deemed to have been their principal residence as a result of 40(4). ...