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Y will be equal to or approximate the amount determined by the formula (A x B/C) + D as found in subparagraph (b)(iii) of the definition of "permitted exchange" in subsection 55(1). ...

Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

In two separate technical interpretations (see 9112095 and 9708635), the Income Tax Rulings & Interpretations Directorate of Revenue Canada opined that a partnership can be a party to a section 16.1 election as either a lessee or a lessor. ...

Reasons: See File # 980159 and 983032. "Travel expenses" includes air, train and bus fares, meals, hotel and motel accommodations, camping fees, incidentals such as taxis, road and ferry tolls, and automobile expenses directly related to the trip such as the cost of fuel, general maintenance (ex. oil, grease and servicing charges), repairs, licenses, and insurance as long as the costs are reasonable, are not on account of capital, and can reasonably be attributed to the trip. ...

The prizes and awards (hereinafter referred to as "awards") for which you have requested our views are as follows: (1) Governor General's Literary Award (13) Governor General's Award in Visual & Media Arts (2) Canada-Japan Literary Award (14) Izaak Walton Killam Memorial Prize (3) Healey Willan Prize for Amateur Choirs (15) Canada Council Grand Prize for CBC Young Composers Competition (4) Canada Council for the Arts Molson Prize (16) Canada Council/CBC First Prize for CBC Young Performers Competition (5) Glenn Gould Prize (17) Virginia Parker Prize (6) Bell Canada Award in Video Art (18) Jean Marie Beaudet Award (7) John Hirsch Prize (19) Sylva Gelber Foundation Award (8) Petro-Canada Award for New Media (20) Robert Fleming Prize (9) Jules Léger Prize for New Chamber Music (21) Duke and Duchess of York Prize in Photography (10) Jacqueline Lemieux Prize (22) Joseph S. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Bco owns XXXXXXXXXX % of the shares of a LLC formed in the U.S. which, in turn, owns shares of three LCCs, which own directly properties located in the U.S.. ...

Limitation of liability The effect of registration as an LLP is set out in subsection 11.1(1) of the Alberta Partnership Act which states: "... a partner in an Alberta LLP is not individually liable directly or indirectly, by means of indemnification, contribution, assessment or otherwise, for debts, obligations or liabilities of the partnership or another partner that arise from the negligence, wrongful acts or omissions, malpractice or misconduct of (a) another partner, or (b) an employee, agent or representative of the partnership, that occur in the ordinary course of carrying on practice in an eligible profession within the meaning of section 79.1 while the partnership is an Alberta LLP. ...

Interpretation Bulletin IT-91R4 "Employment at Special or Remote Work Locations" explains the terms "remote work location " and "special work site" and provides further details concerning the criteria for these exemptions. ...

In stating that the definition of partnership would be satisfied, even where profit making or profit sharing was such an ancillary purpose, Bastarache J. cited the following extract from Lindley & Banks on Partnership: "...if a partnership is formed with some other predominant motive (other than the acquisition of profit)... but there is also a real, albeit ancillary, profit element, it may be permissible to infer that the business is being carried on "with a view to profit". ...