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2 January 2025 External T.I. 2024-1020361E5- Indian Act Tax Exemption & Employment Income Unedited CRA Tags ITA para. 81(1)(a); IA s. 87 Principal Issues: Whether the employment income of the Employees is situated on a reserve and exempt from income tax under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act. ...

13 February 1997 CTF Roundtable Q. 1, 9621950- 1996 ONTARIO TAX CONFERENCE- QS & AS Unedited CRA Tags 212(1)(d) 55(2) 55(3) 112(3.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... First Scenario Purchase of First 50 Shares- capital dividend capital loss500,000 s. 112(3.2) reduction*(375,000) reduced loss125,000 * The subsection 112(3.2) reduction is: 500,000- capital dividend (125,000)- 25% of capital gain on death on 50 Class A shares 375,000 Purchase of Second 50 Shares- taxable dividend capital loss500,000 s. 112(3.2) reduction nil loss500,000 Total Loss First 50 shares 125,000 Second 50 shares 500,000 Total 625,000 Second Scenario capital loss1,000,000 s. 112(3.2) reduction* (250,000) reduced loss750,000 *The subsection 112(3.2) reduction is: the lesser of $500,000 (the capital dividend) and $1,000,000 (the loss otherwise determined) minus $250,000 (25% of the capital gain on death on 100 Class A shares) Response Yes. ... Question #2 If a taxpayer develops computer software for use in the taxpayer's business (not for resale), using internal resources, and the expenditures do not qualify as Scientific Research & Development Expenditures ("SR&ED"), does the taxpayer have to capitalize these costs or can these costs be deducted on a current basis? ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement Unedited CRA Tags 110(1)(d) 251(5)(b) Reg 6204(1) Reg 6204(3)(a) Principal Issues: Will the corporation that acquired the shares of the target Canadian public corporation be a "specified person" for purposes of subsection 6204(1) of the Income Tax Regulations? ...

2 August 2013 External T.I. 2013-0475261E5- Eligible Dividend- Late Filing 89(14.1) & 184(3) CRA Tags 184(2) 89(14) 89(14.1) 184(3) Principal Issues: Whether, in the context of the particular hypothetical situation, subsection 89(14.1) of the Income Tax Act (the "Act") would apply at the time that an election is made for the purposes of subsection 184(3), such that the designation under subsection 89(14) would be deemed to be made at the time the designation is required to be made, with the result that the separate taxable dividend pursuant to subsection 184(3) is designated to be an eligible dividend? ...

Apprenticeship Employer Signing Bonus & ATTC Unedited CRA Tags Section 89, Taxation Act, 2007 [Ontario] (OTA) Principal Issues: 1. ...

E9821495- FOREIGN AFFILIATES- FOREIGN TAX / LLCS Unedited CRA Tags 113(1)(c) 113(1)(b) 91(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

30 June 1997 Internal T.I. 7M1526A- T4 REPORT & WITHHOLD RE PAY. ...

15 December 1998 External T.I. 9821495- FOREIGN AFFILIATES- FOREIGN TAX / LLCS Unedited CRA Tags 113(1)(c) 113(1)(b) 91(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

30 November 1997 Ruling 9806133- FOREIGN PROPERTY & LOAN TO SUBSIDIARY Unedited CRA Tags 104(6) 206(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

16 July 1996 External T.I. 9604915- 55(2)-NOT APPLY WHERE SALE & REDMPTION DIFFERENT SERIES. ...