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Income Tax Convention (the " Convention") applies to exclude the amount. ...

Since this amount does not exceed 80% of the amount paid to the charity, the charity may issue a tax receipt for an eligible amount of $ 47,700 ($100,000 minus $52,300). ...

February 27, 2003 Individual Returns and Headquarters Payments Processing Directorate Income Tax Rulings Pensions & Trusts Section Directorate G. ...

In Income Tax Technical News No. 10, dated July 11, 1997, it is stated that: Revenue Canada has traditionally taken the view that a net profits interest (NPI) would constitute a CRP where it entitled the holder to share in the net proceeds from the production and sale by the grantor of the NPI of oil or gas (footnote 1), or the output from a mineral resource in Canada. [...] the Department will accept that in situations similar to the above, an NPI can qualify as a CRP where the conditions of the NPI provide that 90% or more of the total payments for each particular year under the NPI will directly relate to the amount or value of the NPI grantor's production during that year from: i) an oil or gas well in Canada; ii) a natural accumulation of petroleum or natural gas in Canada; or iii) a mineral resource in Canada from which the NPI was granted and, in addition, the remaining payments will be connected to the operation of the above resource property from which the NPI was granted (the "90% test"). ...

In summary, if the first series qualified for distribution to the public, any of the following scenarios would enable the trust to qualify: 150 unitholders of 100 units of the first series; 150 unitholders of 25 units of the second series; (150- N) unitholders of 100 units of the first series + N unitholders of 100 units of the second series. ...

The ownership of share capital and XXXXXXXXXX debt of the Company as at XXXXXXXXXX is summarized as follows (the group collectively is referred to herein as "the Shareholders" and any of the following is referred to herein as a "Shareholder"): Shareholder # of Shares XXXXXXXXXX Debt XXXXXXXXXX The Shareholders of the Company are not related to any other Shareholder within the meaning of "related persons" provided in subsection 251(2) of the Act. 5. ...

Principal Issues: Whether a reduction in mgt fees for some unitholders causes 104(7.1) to deny a deduction under 104(6) and whether the proposed changes cause the funds to lose their status as unit trusts Position: 1: No 2: No Reasons: See previous rulings 941353, 942514 & opinion 901041 XXXXXXXXXX XXXXXXXXXX 991267 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling We are writing in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-noted trust and beneficiaries under the trust in respect of the income tax consequences arising out of the proposed transactions described below. ...

Dans ce jugement, il est indiqué que le tribunal croit qu'il y a lieu de fixer la pension alimentaire dont Madame a besoin et que Monsieur pourrait lui payer à XXXXXXXXXX $ par mois. ...

Principal Issues: Where an income distribution reinvestment plan of a unit trust enables a unitholder to reinvest income distributions in new units at a price equal to XXXXXXXXXX % of the average market price and without commission or service charge, will a benefit be considered to be conferred pursuant to subsection 105(1)? ...

You posed this question: With the introduction of section 80.4(1.1)(b), to the extent evidence clearly exists that " it is reasonable to conclude that...the debt would not have been incurred" were it not for the employee's relocation, notwithstanding the introduction of section 6(23), would the taxable benefit under such arrangements be computed in accordance with the provisions of section 80.4? ...