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Technical Interpretation - External

6 July 2020 External T.I. 2020-0840271E5 - Indian Employment Income

6 July 2020 External T.I. 2020-0840271E5- Indian Employment Income Unedited CRA Tags 81(1)(a) * Principal Issues: Whether the employment income earned by Indians that benefit Indigenous women who live off-reserve is exempt from tax. ...
Ruling

2020 Ruling 2020-0869891R3 - Supplemental Ruling

2020 Ruling 2020-0869891R3- Supplemental Ruling Unedited CRA Tags 20(1)(c), 112, 245 Principal Issues: Changes to the facts and proposed transactions in advance income tax ruling Position: The rulings in file 2019-081829 will continue to be valid Reasons: The changes do not affect our conclusions XXXXXXXXXX 2020-086989 XXXXXXXXXX, 2020 Re: Advance Income Tax Ruling Request supplement to file 2019-081829 XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX. ...
Technical Interpretation - External

22 February 2021 External T.I. 2018-0784661E5 - Subsection 122.1(1) - Gross REIT revenue tests

The Trust must satisfy paragraph (d) of the REIT Definition, which requires that throughout the trust’s taxation year, the total fair market value of certain qualifying properties namely “real or immovable property” (as defined under subsection 122.1(1)) that is capital property and certain other listed properties- must equal at least 75% of the trust's equity value. ...
Technical Interpretation - External

3 May 2021 External T.I. 2019-0831981E5 - CDE and Pre-Production Revenues

Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Mine Development Expenses incurred after November 16, 1978 and before March 21, 2013 were eligible as CEE under paragraph (g) of the definition of CEE. ...
Technical Interpretation - External

20 December 2021 External T.I. 2021-0911101E5 - Class action settlement payments

Yours truly, Helen Ferrigan A/Section Manager for Division Director Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External

5 December 1990 External T.I. 90M12235 F - Employee Benefit Plans Existing Prior to December 31, 1987

5 December 1990 External T.I. 90M12235 F- Employee Benefit Plans Existing Prior to December 31, 1987 Unedited CRA Tags 125(7) specified investment business, 248(1) small business corporation, 248(4), 249(4), 256   December 5, 1990 S.G. ...
Technical Interpretation - External

10 May 1991 External T.I. 9103195 F - Preferred Beneficiary Election

To show the effect where contingent beneficiaries are concerned, we have considered the grandchildren's rights to arise only on the death of a child. 1.      ...
Ruling

16 June 1989 Ruling 73791 F - Annuity Agreement with a Registered Charity

16 June 1989 Ruling 73791 F- Annuity Agreement with a Registered Charity Unedited CRA Tags 118.1(3), 60(a), 56(1)(d), 104, 75(2)(a)(i)   June 16, 1989 Enquiries and Taxpayer Specialty Rulings Assistance Division Directorate P. ...
Miscellaneous severed letter

13 April 1992 Income Tax Severed Letter 9207126 - Ontario Employee Wage Protection Program

13 April 1992 Income Tax Severed Letter 9207126- Ontario Employee Wage Protection Program April 13, 1992 Other Returns & Guides Division Financial Industries Division P. ...
Miscellaneous severed letter

30 July 1992 Income Tax Severed Letter 9215895 - Deemed and Designated Principal Residences of Surviving Spouse

As a result of this calculation, the capital gain to be included in income from a 1992 disposition of a principal residence which has been owned since 1971 and which has been designated to be a principal residence for the taxation years 1988-1992 inclusive (for example, the years in which the deeming provision does not apply) would be the capital gain calculated in the normal manner for property held on Valuation Day (V-Day) less 6/21 (5+1 / 21) of the capital gain otherwise calculated. ...

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