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14 December 2009 Internal T.I. 2009-0333931I7- Education & Tuition Credit, licence fee deduction Unedited CRA Tags 8, 18, 118.5; 118.6 Principal Issues: 1. ... December 14, 2009 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Income Tax Rulings Client Relations Directorate Directorate Corporate Strategies and Renee Sigouin Business Development Branch (613) 957-2128 ` Attention: XXXXXXXXXX XXXXXXXXXX 2009-033393 Fees paid for courses, exams and licences We are writing in response to your email correspondence dated July 24, 2009 wherein you requested our comments with respect to whether individuals (the "Individuals") taking a particular course and related exam are entitled to claim an education tax credit and/or tuition tax credit and additionally, whether certain licence fees are deductible for income tax purposes. ...

2008 Ruling 2008-0295711R3- Indian Band-Public Body & Function of Government Unedited CRA Tags 149(1)(c) Principal Issues: Is the Indian band a public body performing a function of government? ... This GIC will earn interest at a rate of XXXXXXXXXX %. Purpose of the Proposed Transaction The purpose of the proposed transaction is to generate additional income for the Indian Band to fund and support the governance, public works, infrastructure, social services and general development of the Indian Band. ...

13 May 2002 Internal T.I. 2002-0116807- M & P- COST OF LABOUR Unedited CRA Tags 125.1 5202 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... DISCUSSION The relevant portion of the definition of "cost of labour" of a corporation for a taxation year in section 5202 of the Regulations provides as follows: " an amount equal to the aggregate of (a) the salaries and wages paid or payable during the year to all employees of the corporation for services performed during the year, and (b) all other amounts each of which is an amount paid or payable during the year for the performance during the year, by any person other than an employee of the corporation, of functions relating to (i) the management or administration of the corporation, (ii) scientific research and experimental development, or (iii) a service or function that would normally be performed by an employee of the corporation. ...

7 November 2002 CTF Roundtable Q. 1, 2002-0144140- CTF STEWART & WALLS Unedited CRA Tags 9 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Principal Issues: 2002 Canadian Tax Foundation Q & A regarding the Supreme Court of Canada decisions in Stewart and Walls. ...

28 July 1989 Income Tax Severed Letter AC738342- 99-Year Leases- Abalone & Roe Herring Licences Unedited CRA Tags 14(5) July 28, 1989 VANCOUVER DISTRICT OFFICE HEAD OFFICE Chief of Audit Financial lndustries Division Kevin J. ... Hannemann 7-3842 SUBJECT: 99 Year leases Abalone & Roe Herring Licences Your memorandums dated March 14, 1989 and May 1st 1989 addressed to Head Office, Audit Applications Division, have been referred to this Division with a view to providing you with the opinions requested. ...

22 August 1988 Income Tax Severed Letter 5-6100- [] C.R. Bowen (613) 957-2094 XXXX August 22 1988 Dear Sirs: We are writing in reply to your letter of May 24, 1988, wherein you seek our confirmation that a particular facility would qualify as a "certified property" as opposed to a "qualified property" for investment tax credit purposes. ... The word "facility" is defined in section 2 thereof as meaning " the structures, machinery and equipment that constitute the necessary components of a manufacturing or processing operation... ...

2009 Ruling 2009-0336261R3- transferable warrants & flow through shares Unedited CRA Tags 66(15); 66(12.6); 66(12.66) Principal Issues: 1. whether transferable flow-through warrants qualify as FTS Position: 1.if all conditions of definition in 66(15) met at the time warrant is exercised Reasons: 1. based on proposed transactions "agreement in writing" and other required conditions will be met when warrant is exercised XXXXXXXXXX 2009-033626 XXXXXXXXXX, 2009 Dear. ... The common shares of the Corporation are listed on the XXXXXXXXXX under the ticker symbol "XXXXXXXXXX " and are widely held by the public. 4. ... In particular, nothing in this letter should be interpreted as confirming, either expressly or implicitly: (i) whether the Corporation is a principal-business corporation; (ii) whether any particular expense incurred or to be incurred by the Corporation will qualify as CEE; (iii) whether any particular expense incurred or to be incurred by the Corporation will constitute a prescribed Canadian exploration and development overhead expense; (iv) the determination of whether the Warrant Shares will constitute prescribed shares; (v) the reasonableness of the allocation of the $ XXXXXXXXXX subscription price payable for a Series B Unit as described in paragraph 5(iii); and (vi) the computation of the adjusted cost base of the Series B Warrant to the Holder and the computation of the cost of the Warrant Share to the Holder and, in particular, the interaction of subsections 49(3) and 66.3(3). ...

2007 Ruling 2006-0215921R3 F- Don à une municipalité / 149(1)l) Unedited CRA Tags 248(31) 248(32) 149(1)l) Principales Questions: (1) Quel est le montant admissible d'un don fait à une municipalité lorsque la municipalité entend verser un montant équivalent à un organisme sans but lucratif (OSBL) à la suite du don? ... Entité C XXXXXXXXXX Entité D XXXXXXXXXX Entité E XXXXXXXXXX Entité F DÉFINITION DES TERMES Don Le don à être effectué par Société A à Entité B d'un montant de XXXXXXXXXX $. ... Montant du Don XXXXXXXXXX $. Période La durée de l'Emphytéose qui sera, au minimum, de XXXXXXXXXX ans. ...

Health & Welfare Type Trusts Unedited CRA Tags 94 94.1 Principal Issues: 1. are participants "beneficially interested" in the trust? ... The definition of "arm's length transfer" in proposed subsection 94(1) of the Act reads in part as follows: "arm's length transfer", at any time by an entity (referred to in this definition as the "transferor") means a transfer or loan (which transfer or loan is referred to in this definition as the "transfer") of property (other than a restricted property) that is made at that time (referred to in this definition as the "transfer time") by the transferor to a particular entity (referred to in this definition as the "recipient") where (a) it is reasonable to conclude that none of the reasons (determined by reference to all the circumstances including the terms of a trust, an intention, the laws of a country or the existence of an agreement, a memorandum, a letter of wishes or any other arrangement)for the transfer is the acquisition at any time by any entity of an interest as a beneficiary under a non-resident trust; and (b) the transfer [...] (iv) is a transfer (A) in exchange for which, the recipient transfers or loans property (other than a restricted property) to the transferor, or becomes obligated to transfer or loan property (other than a restricted property), and (B) for which it is reasonable to conclude (I) having regard only to the transfer and the exchange that the transferor would have been willing to make the transfer if the transferor dealt at arm's length with the recipient, and (II) that the terms and conditions, and circumstances, under which the transfer was made would have been acceptable to the transferor if the transferor dealt at arm's length with the recipient, [...] ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1) CRA Tags 18(6) 212(3.1) 17(2) Principal Issues: What is the requisite degree of linkage, between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, sufficient to potentially engage subsection 18(6.1) and 212(3.2), respectively? ...