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11 October 2013 Internal T.I. 2013-0475761I7- Deadline for filing a waiver of tax credit – ORDTC CRA Tags 150(1)(a) & 127(9)(m) of the ITA 43(1) and 38(1) 2 2007 & (3) of the Taxation Act Principal Issues: Can a corporation file a waiver of tax credit under subsection 43(1) of the Taxation Act, 2007 (TA) to waive all or part of its ORDTC after the deadline for the filing of its income tax return for the year? ...

9 November 2012 External T.I. 2012-0460471E5- T5013 & non-Canadian partnership CRA Tags ITR 805.1 ITR 229(1) ITR 805 Principal Issues: Does a member of a partnership that is not a Canadian partnership have to file a partnership information return (i.e. ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act CRA Tags Bankruptcy and Insolvency Act 13 164(2.01) 241(4)(k) 241(5) 128 150(3) Bankruptcy and Insolvency Act 22 Principal Issues: 1. ...

6 May 2016 External T.I. 2016-0646411E5- Professional corporation & small business deduction CRA Tags 125 Principal Issues: Impact of 2016 Budget on partnership reorganization rulings Position: See Below Reasons: See proposed legislation in 2016 Budget and paragraph 16 of IC70-6R7. ...

2 May 2012 Ministerial Correspondence 2012-0438981M4- Children's Arts & Fitness Tax Credits Unedited CRA Tags 118.03; 118.031; 9400 and 9401 of ITR Principal Issues: Should there be splitting the receipts from a dance studio where students partake in both song and dance, both being eligible activities for each of the respective tax credits? ...

7 July 2016 External T.I. 2015-0595481E5- Ontario Corporate Minimum Tax – Forgiven Debt Unedited CRA Tags 56(1), 57(1) of the Taxation Act, 2007 Principal Issues: Whether a forgiven amount is included in adjusted net income for Ontario corporate minimum tax (CMT) purposes. ...

13 October 2011 External T.I. 2010-0369811E5- Payments to Caregiver / Social Assistance Unedited CRA Tags ITA 81(1)(h); 56 (1)(u) Principal Issues: Whether payments received by caregiver under the Persons with Developmental Disabilities Program are excluded from income under paragraph 81(1)(h) of the ITA. ...

10 November 2011 External T.I. 2011-0415841E5- Trade Union & Trust Filing Requirements Unedited CRA Tags s. 149(1)(e), (k), (l); Reg. 204(1) Principal Issues: Whether a trade union or a trust that has been created by the trade union is exempt from filing a T2 Corporation Income Tax Return, a T3 Trust Income Tax and Information Return, and a T1044 Non-Profit Organization Information Return. ...

1 September 2011 External T.I. 2011-0394641E5- Payments to Respite Care Providers & 81(1)(h) Unedited CRA Tags 81(1)(h) Principal Issues: 1. ...

7 January 2011 Internal T.I. 2010-0384911I7- Education & Textbook Tax Credits Unedited CRA Tags 118.6(1), 118.6(2.1) Principal Issues: If an individual received reimbursement from their employer for one of four courses taken at a designated educational institution, can the "program" consist of the remaining three courses that will allow the individual to claim the education and textbook tax credits. ...