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2007 Ruling 2007-0235881R3- Class of German Arrangement & Treaty Benefits Principal Issues: 1. ... In this letter, unless otherwise noted all statutory references are to the Income Tax Act (Canada), R.S.C. 1985, 5th Supplement, c. 1, as amended, (the "Act") each "technical" tax term used in this request has the same meaning as it has for purposes of the Act and each monetary reference is to CDN $. ... The Fund will be the only limited partner of the LP and will hold a XXXXXXXXXX% limited partnership interest and Newco will be the only general partner of the LP and will hold a XXXXXXXXXX % general partnership interest. 42. ...

3 June 2011 STEPs Roundtable Q. 2, 2011-0401831C6- 2011 STEP Conference-Q2-Trusts & Principal Res. ...

2 July 2013 External T.I. 2012-0454251E5- 149(1)(l) – donations to capital fund CRA Tags 248(31) 149(1)(l) Principal Issues: 1. ...

2014 Ruling 2014-0532411R3- Convertible Notes & Part XIII Tax CRA Tags 212(3) 212(1)(b) 214(7) Principal Issues: In the event of a conversion of a convertible note for common shares, whether the excess (if any) determined under subsection 214(7) would constitute "participating debt interest" as defined in subsection 212(3)? ...

18 June 2015 STEP Roundtable Q. 10, 2015-0578541C6- 2015 STEP – Q10- Interest in a Trust as TCP CRA Tags 116(5.01) 116(6.1) 116(5.02) 116(6) 116(5) 248(1) Principal Issues: A testator leaves an estate, more than 50% of which is comprised of real property situated in Canada, (the testator's principal residence). ...

31 October 2011 Internal T.I. 2011-0421911I7- Stock options- 181.2(4) & GAAP XXXXXXXXXX Unedited CRA Tags 181.2(4)(a) Principal Issues: Does an amount on the balance sheet representing stock options issued to employees of indirect subsidiaries qualify for an investment allowance in the calculation of the issuing corporation's taxable capital pursuant to paragraph 181.2(4)(a)? ...

2 February 2012 External T.I. 2011-0423231E5- METC- Yoga Fees & Travel expenses Unedited CRA Tags 118.2(2)(g), (h) Principal Issues: 1- Whether yoga fees qualify as eligible medical expenses for the purposes of the medical expense tax credit ("METC") if recommended by a doctor. 2- Whether an individual can claim the travel expenses of more than one accompanying individual as eligible medical expenses for the purposes of the METC. ...

29 October 2010 External T.I. 2010-0377091E5- Liability for interest & penalties of late estate Unedited CRA Tags 150(1)(b) Principal Issues: Who, if anyone, is liable for interest and penalties of the estate of a deceased individual? ...

29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning Unedited CRA Tags 104(4); 104(5.8); 107(2); 245 Principal Issues: Implications of a transfer of property from a discretionary trust to a Canadian corporation wholly owned by a new discretionary trust Position: CRA will typically apply GAAR in this situation. ...

18 September 2009 Internal T.I. 2009-0318451I7- Language Training- Tuition & Education Tax Credit Unedited CRA Tags 118.5; 118.6 Principal Issues: Is second language training (French or English) at HRSDC certified educational institutions eligible for the tuition tax credit? ...