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4 January 2011 External T.I. 2008-0289051E5- Section 116 & Treaty Protected Property Unedited CRA Tags 116(5.01) Principal Issues: (1) In a transfer between parties that are not related persons, in order for the property transferred to qualify as "excluded property" pursuant to paragraph 116(6)(i) of the Act, does the notice described in subsection 116(5.02) have to be filed if the property is "treaty-protected property" as that term is defined in subsection 248(1)? ...

4 June 2009 Internal T.I. 2009-0314631I7- Taxation & Insolvency Unedited CRA Tags S. 168(1) Excise Tax Act S. 152(1) Excise Tax Act S. 296(1)(b) Excise Tax Act Principal Issues: Whether an assessment under s. 296(1)(b) of the Excise Tax Act predates the filing of a proposal under the Bankruptcy and Insolvency Act Position: Yes. ...

21 July 2009 Ministerial Correspondence 2009-0327131M4- HRTC- Eligible expenditures & individual projects Unedited CRA Tags January 27, 2009 Federal Budget- Annex 5 Principal Issues: Would a homeowner be eligible to claim the home renovation tax credit (HRTC), if he/she decides to perform the work himself/herself. ...

8 June 2007 Roundtable, 2007-0240431C6- 2007 STEP Conf-Q. 12-Change in Trustees & Cntrl Unedited CRA Tags 257(7)(a) 256(1) Principal Issues: Can the CRA advise if there have been any further developments on the issue of whether a change in any of the trustees of a trust would result in a change in control of the corporation of which the trust is the shareholder? ...

12 May 2006 External T.I. 2005-0159581E5- "Approved " Status Unedited CRA Tags 37(1)(a)(ii) 37(7) Principal Issues: The client requested that XXXXXXXXXX. be approved as a not-for profit corporation entitled for third party payments for SR&ED. ...

21 December 2006 Roundtable, 2006-0215491C6- timing recognition foreign currency gains & losses Unedited CRA Tags 39(2) Principal Issues: When to report a foreign currency gain or loss in respect of funds denominated in a foreign currency on deposit for the purposes of the Act Position: Depends on whether the gain or loss is on account of capital or on revenue account. ...

2 June 2005 External T.I. 2005-0116801E5- Airplane Lease Costs & Withholding Tax Unedited CRA Tags 6(1)(a) 15(1) 212(1)(d)(xi) Principal Issues: Canco leases an airplane from USco for use in the shareholder's business travel. 1. ...

17 June 2005 External T.I. 2005-0134441E5- Labour Association Annulment & Bank Balance Unedited CRA Tags 8(1)(i) 8(5) 149(1)(k) Principal Issues: Whether the payment of the labour association's bank balance after its annulment to its current members would affect its non-taxable status Position: No. ...

1 December 2005 External T.I. 2005-0155975E5- Cellular Phone Airtime Minutes & Taxable Benefits Unedited CRA Tags 6(1)(a) Principal Issues: Whether an employee's personal use of airtime minutes of an employer provided cellular phone plan represent a taxable benefit under paragraph 6(1)(a) Position: Question of Fact. ...

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty Unedited CRA Tags Articles IV(1), IV(6), IV(7) and X(2) of the Canada-U.S. ...