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31 October 1989 Income Tax Severed Letter AC58322- SR & ED- Approved Association or Research Institute R. Albert (613) 957-2098 19(1) October 31, 1989 Dear Sirs: Re: Subparagraph 37(1)(a)(ii) of the Income Tax Act (the "Act") We are writing in reply to your letter of July 7, 1989 and subsequent telephone discussion concerning the taxation implications of the provisions of subparagraph 37(1)(a)(ii) of the Act. 19(1) Clause 37(1)(a)(ii)(E) of the Act provides for the deduction of payments made to "an approved organization that makes payments to an association, institution or corporation described in any of clauses (A) to (C)" to be used for scientific research and experimental development ("SR & ED") carried on in Canada, related to a business of the taxpayer, and provided that the taxpayer is entitled to exploit the results of such SR & ED. ... The Assistant Deputy Minister of Revenue Canada, Taxation will grant approval to an association or an institute if it meets the following criteria: a) it has the facilities and personnel capable of carrying out SR & ED, b) it carries on only activities that are unquestionably SR & ED, c) the typical requirements for non-profit status are satisfied, such as no personal benefit to members, no control of other associations, satisfactory provisions for distribution of assets on dissolution, etc., d) the general public will be a beneficiary of the results of successful SR & ED, and e) the funding of the organization will be sufficient to ensure continued research by it. ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty Unedited CRA Tags 212(1)(b)(ii), 212(3) “participating debt interest”; Art. ... Under the Canada-US Tax Convention (the “Treaty”) however, interest paid by a resident of Canada to a resident of the United States that is entitled to the benefits of the Treaty is not subject to Canadian withholding tax, other than interest: “arising in Canada that is determined with reference to receipts, sales, income, profits or other cash flow of the debtor (…), to any change in the value of any property of the debtor (…) or to any dividend, partnership distribution or similar payment made by the debtor...” ... Yannick Roulier / Nicolas Bilodeau 2019-079874 May 15, 2019 ...

15 June 2006 External T.I. 2006-0183921E5- Definition of Canada & Reg.105 Unedited CRA Tags 255 Reg.105 Principal Issues: (1) Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals... ... XXXXXXXXXX 2006-018392 June 15, 2006 Dear XXXXXXXXXX: Subject: Definition of "Canada" & Section 105 of the Income Tax Regulations This is in response to your request for our view on whether the extended definition of Canada in section 255 of the Income Tax Act (the "Act") applies in the circumstances set out below. ... Question 1 1-) Section 255 of the Act & Section 105 of the Regulations The term " Canada" is not defined in the Income Tax Act. ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS Unedited CRA Tags 149(10) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... SUMMARY FILE # 933101 Principal Issues: Whether a corporation going from non-taxable to taxable status & therefore subject to 149(10) can claim a terminal loss Position TAKEN: Yes. ...

20 June 2023 STEP Roundtable Q. 4, 2023-0968111C6- Trust Reporting – Definition of Beneficiary Unedited CRA Tags 204.2 Principal Issues: Does subsection 204.2(1) of the Income Tax Regulations apply to a contingent beneficiary? ... Reasons: Question of the relevant facts and law. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 4. Trust Reporting – Definition of Beneficiary Pursuant to paragraph 204.2(1)(a) of the Income Tax Regulations (the “Regulations”), a trustee of a trust (unless the trust is subject to one of the exceptions in subsection 150(1.2) of the Income Tax Act (the “Act”) (footnote 1)) is to report information about each beneficiary of the trust, subject to subsection 204.2(2) of the Regulations. ...

21 April 1992 Ministerial Letter 9309928 F- Indians and Employment Income — 36 Indian Act Unedited CRA Tags 81(1)(a) ADM'S OFFICE ADM930291 CENTRAL RECORDS RETURN TO RULINGS, ROOM 303, MET. ... For instance, it has already been determined that the exemption will apply to:-     employment income for duties performed entirely on a reserve;-     employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve;-     employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and-     unemployment, pension and retiring benefits received in respect of exempt employment income. ...

30 November 2012 Internal T.I. 2012-0458491I7- Private School – Non-profit organization CRA Tags 149(1)(l) Principal Issues: Does the entity qualify as a non-profit organization pursuant to paragraph149(1)(l) of the Act Position: No Reasons: The entity operates a private high school for the purpose of earning profit. November 30, 2012 Specialty Audit Section, Headquarters Specialty Audit Division IT Rulings Directorate Small & Medium Enterprises Directorate A. ... Founded in XXXXXXXXXX, the school currently has about XXXXXXXXXX students, XXXXXXXXXX % of whom are international students and the remaining XXXXXXXXXX % Canadian. 2. ...

19 May 1995 External T.I. 9423885 F- CRITERES \ CONTROLE DE FAIT Unedited CRA Tags 256(5.1) 256(1)b) 256(3) 256(6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... A détient 70 % des actions ordinaires de la société X, l'autre 30 % est détenu en parts égales par trois de ses fils. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1) Unedited CRA Tags 250(1)(a) ART IV and XV REG 105 110(1)(f)(i) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... We are not able to find any references in the case of R & L Food Distributors Ltd. 1 ("R & L") described in your letter that a "day" refers to each 24 hour period. ... Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Policy and Legislation Branch 1 R & L Food Distributors Ltd. v. ...

18 December 1989 Income Tax Severed Letter AC74225- SR & ED Qualifying Expenditures W.A. ... Our interpretation of those requirements is as follows: a) Clause (A) includes an expenditure which is incurred for and all or substantially all of which is attributable to the prosecution, or to the provision of premises, facilities equipment for the prosecution, of SR & ED in Canada: Paragraph 37(7)(b) of the Act defines SR & ED as having the meaning given by subsection 2900(1) of the Regulations. ... Thus to qualify under clause (A) an expenditure must be both incurred for and 90% or more attributable to SR & ED as defined in subsection 2900(1) of the Regulations. ...