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On XXXXXXXXXX, 2005, a favourable advance income tax ruling (our file # 2004-010307) was issued concerning expenses qualifying under paragraph (f) of the definition of CEE related to proposed exploration drilling programs to be undertaken on three other zones on the Property. ...

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Nous vous référons cependant aux paragraphes 22 à 26 du Bulletin d'interprétation IT-419R2, Définition de l'expression "sans lien de dépendance ", en date du 8 juin 2004, qui exposent les lignes directrices générales suivies par l'ARC pour déterminer si des personnes ont entre elles un lien de dépendance ou non à un moment donné. ...

The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. [...]. ...

Those services are rendered on a cost recovery basis plus XXXXXXXXXX %. ...

Prior to the December 2007 amendments, the Expenditure Deductible Condition read as follows (emphasis added): “expenditures … that are or would, if the partnership were a foreign affiliate of the taxpayer, be deductible in the year or a subsequent taxation year by the other affiliate or the partnership in computing the amounts prescribed to be its earnings or loss from an active business” The December 2007 amendment to “old” clause 95(2)(a)(ii)(B) was part of a large package of proposed amendments to the Act released by Finance on October 2, 2007 and, in our view, that amendment was a tightening measure consistent with the repeal of “old” clause 95(2)(a)(ii)(A) which had been proposed in Budget 2007 and implemented by the same December 2007 amendments. ...

XXXXXXXXXX 2017-072090 XXXXXXXXXX, 2018 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX – Business Number XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling on behalf of the above-noted taxpayer. ...

Reasons: The definition of a "participating debt interest" refers to interest "that is paid or payable on an obligation, all or any portion of which …". ...

Yours truly, for Director Resources, Partnerships & Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 7- ...

Reasons: See Rulings file # 9803275, 9224985, 9614505, 913418. XXXXXXXXXX 982918 G. ...