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Murphy Manager Trusts Section Resources, Partnerships & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

November 20, 2012 Small & Medium Enterprises Directorate HEADQUARTERS 112 Kent Street, 19th Floor Income Tax Rulings Ottawa, ON K1A 0L5 Directorate Lori Merrigan (613) 957-9229 Attention: Gilles Rochette 2012-043995 XXXXXXXXXX (the “Association”) This is in response to your correspondence of March 15, 2012, asking for our comments with respect to the tax-exempt status of the Association pursuant to paragraph 149(1)(l) of the Income Tax Act (the “Act”). ...

February 13, 2013 SME Income Tax, Audit Division Ananthy Mahendran Section 442-31, CEW-04, Sinclair 905-721-5204 VTSO Attention: Theresa Ohene-Asante A/Team Leader, Workload Development 2012-044839 Validity of Late-filed Principal Residence Election and Designation This is in response to your correspondence dated May 15, 2012, and our telephone conversation on July 5, 2012 (Mahendran / Ohene-Asante), wherein you requested our views on the validity of the principal residence election and designation in the circumstances described in your correspondence. ...

Position: Likely no Reasons: Fact specific November 21, 2012 Small & Medium Enterprises Directorate HEADQUARTERS 112 Kent Street, 19th Floor Income Tax Rulings Ottawa, ON K1A 0L5 Directorate Ann Townsend 905-721-5096 2012-045550 Attention: Rubin Dressler Non Profit Organization (“NPO”) Project- XXXXXXXXXX (the “Corporation”) This is in response to your correspondence of July 10, 2012, asking for our comments with respect to the tax-exempt status of the Corporation pursuant to paragraph 149(1)(l) of the Income Tax Act (the “Act”) for the XXXXXXXXXX and XXXXXXXXXX taxation years. ...

" The Residential Tenancies Act, 2006 (Ontario) states that "rent" includes, " the amount of any consideration paid or given or required to be paid or given by or on behalf of a tenant to a landlord or the landlord's agent for the right to occupy a rental unit and for any services and facilities and any privilege, accommodation or thing that the landlord provides for the tenant in respect of the occupancy of the rental unit, whether or not a separate charge is made for services and facilities or for the privilege, accommodation or thing... ...

We also acknowledge several discussions concerning the file (Godson, Young / Bafia, Holly Carswell). ...

August 26, 2013 Blair Hammond Angelina Argento Senior Advisor – Tax Treaties IT Rulings Directorate International, Provincial and (514) 283-7895 Strategic Policy Division Legislative Policy Directorate 2013-049421 Subparagraph 6(b) of Article XI of the Canada-U.S. ...

At the time of the investment, the exchange rate was $1US = $1 Canadian. ...

The Taxpayer’s activities carried on in Canada consist primarily of XXXXXXXXXX, in order to satisfy the shipping requirements of certain related companies – XXXXXXXXXX (the “Related Party Customers”) XXXXXXXXXX. 3. ...

Either the non-resident corporation does not have a tax reporting currency, or it has the Canadian dollar tax reporting currency – the same as the Canadian-resident corporation. ...