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May 20, 2010 Patrick Massicotte Income Tax Rulings Senior Analyst Directorate Competent Authority Services Yannick Roulier International & Large Business, Compliance Programs (613) 957-2134 Canada Revenue Agency Enterprise Building 427 Laurier Ave. ...

September 9, 2010 WINNIPEG TAX CENTRE HEADQUARTERS Individual & Benefit Services Division Income Tax Rulings Directorate Attention: Cyndi Martin-Conway Rita Ferguson 519-645-5261 2010-037408 Deduction of Legal Fees We are writing in response to your request for a Technical Interpretation on the matter of expenses deductible under paragraph 60(o) of the Income Tax Act (the "Act"). ...

The XXXXXXXXXX stresses on "XXXXXXXXXX " It is reasonable to assume that there is a sense of communality with in the organization. ...

May 19, 2009 Calgary TSO- Audit Division Income Tax Rulings Directorate 220- 4 Ave SE, Rm 130 Financial Sector & Exempt Entities Harry Hays Building Division Calgary, Alberta Robert Demeter, CGA T2G 0L1 (613) 952-1505 Attention: Tom Olsen 2009-031331 XXXXXXXXXX Part I.3 Implications, Central Banking Arrangement This is in response to your request for interpretation initiated on March 10, 2009. ...

" Although the Act does not specify what is meant by "meeting clients", the Oxford Canadian dictionary defines "meeting" as "an assembly of people and defines "meet" as: " a. encounter (a person or persons) by accident or design; come face to face with, b. ...

" [Emphasis added]. In my opinion, s. 12(1) operates so as to expand s. 9(1)'s ambit of inclusion. ...

Although the Act does not specify what is meant by "meeting clients", the Oxford Canadian dictionary defines "meeting" as "an assembly of people and defines "meet" as: " a. encounter (a person or persons) by accident or design; come face to face with, b. ...

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

Section 808(2) of the Regulations defines a corporation's "qualified investment in property in Canada at the end of the year" to include: (g) an amount equal to the aggregate of the cost amount to the corporation at the end of the year of each debt (...) owing to it (i) in respect of any transaction by virtue of which an amount has been included in computing its income for the year or from a previous year from a business carried on in Canada; or (i) an amount equal to the allowable liquid assets of the corporation at the end of the year. ...

Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...