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Ruling

2011 Ruling 2011-0396421R3 - Permanent Establishment

(d) "XXXXXXXXXX " is described in Paragraph 2. (e) "CRA" means the Canada Revenue Agency. ...
Technical Interpretation - Internal

28 July 2011 Internal T.I. 2011-0394981I7 - Cooperative Housing and 149(1)(l)

C.35: Subsection 55(1) "... [T]he surplus arising from the business of a co-operative... in each fiscal year shall be allocated, credited or paid to the members in proportion to the business done by each member with or through the co-operative... ...
Technical Interpretation - External

3 October 2011 External T.I. 2011-0396601E5 - education tax credit and textbook tax credit

The Resident Program in our opinion seems to be more of a training program provided by the Resident's employer, the various hospitals in XXXXXXXXXX, where according to the information provided, the training and instruction seems to be provided, and designed so the doctors can prepare for examinations given by the Medical Council of Canada so they can be licensed by the College of Physicians & Surgeons of XXXXXXXXXX to practice medicine rather than, a qualifying educational program where a student is engaged in academic course study at a designated educational institution. ...
Ruling

2010 Ruling 2010-0383661R3 - Carrying on Business in Canada

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal

13 April 2010 Internal T.I. 2010-0358541I7 - Annual gains limit

As explained by Ottawa TSO's Appeals Division, the Rep's position after reviewing the calculation in the TSO's schedule is as follows: "XXXXXXXXXX " Our Comments In our view, the amount of net capital losses deducted under paragraph 111(1)(b) in XXXXXXXXXX that is to be taken into account in computing the amount referred to in subparagraph (a)(i) of parameter B in the definition of the AGL in subsection 110.6(1), which amount in turn affects the amount determined for paragraph (b) of the definition of CGL, should be $XXXXXXXXXX (i.e., $XXXXXXXXXX less $XXXXXXXXXX). ...
Technical Interpretation - External

15 July 2010 External T.I. 2010-0361991E5 - Personal use of employer's vehicles

Either 6(1)(a) or 6(1)(e) & (k) depending on whether or not the vehicle is considered an "automobile". 3. ...
Technical Interpretation - External

16 February 2011 External T.I. 2010-0389561E5 - Transfer of farm property to "ex" daughter-in-law

The TAB went on to point out (at paragraph 13) the potential absurdities if one were to conclude that the in-law relationship continued after death: "... ...
Ruling

2010 Ruling 2010-0360361R3 - Indian LP - 20(1)(c) Deduction

The interest rate on the Limited Partnership Promissory Note will be the prime rate as statistically monitored by the Bank of Canada plus XXXXXXXXXX %. ...
Ruling

2010 Ruling 2009-0352111R3 - 149.1(1) Related business - persons employed

Our understanding of the relevant definitions, the facts, proposed transaction and its purpose is as follows: DEFINITIONS XXXXXXXXXX; "Charity" means "XXXXXXXXXX ", incorporated pursuant to letters patent issued under the Canada Corporations Act dated XXXXXXXXXX An "employee" means a person employed and remunerated for that employment; and A "volunteer" in respect of the Facility means a person employed by the Charity in the carrying on of a business of the Charity who is not remunerated in any manner whatsoever for that employment. ...
Ruling

2009 Ruling 2009-0317831R3 - Loss Consolidation

Simple interest will accrue on each of the Subsidiary Loans and will be calculated daily at a rate equal to XXXXXXXXXX % per annum. ...

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