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7 August 2015 Internal T.I. 2015-0585011I7- Osteopaths & naturopaths in Quebec CRA Tags 118.4(2) Principal Issues: 1) Whether osteopaths and naturopaths are authorized medical practitioners in the province of Quebec for purposes of the federal medical expense tax credit (METC). 2) Whether Revenue Quebec's brochure entitled "Medical Expenses" can be relied on in determining whether a practitioner is an authorized medical practitioner for the purposes of the federal METC. ... Nadia Zinck Income Tax Rulings GST/HST/QST and Benefits Information Section Directorate Information Programs Division Randa El-Kadi Taxpayer Services Directorate (613) 670-9054 Assessment and Benefit Services Branch 2015-058501 Osteopaths and naturopaths in Quebec – Federal criteria for the medical expense tax credit Dear Ms. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10 Unedited CRA Tags 207.6(2) Principal Issues: 1) What factors does the CRA consider in determining whether the RCA deeming rule in subsection 207.6(2) applies to a particular life insurance policy? ... CALU CRA Roundtable – May 2012 Question 10- Deemed RCA Rules Background Subsection 207.6(2) of the Act deems the RCA rules to apply to situations where 1) the employer has a legal obligation to provide benefits that are to be received or enjoyed by any person on, after, or in contemplation of any substantial change in services rendered by the retirement or loss of an office or employment of a taxpayer; 2) the employer acquires an interest in a life insurance policy; and 3) such insurance policy “may reasonably be considered to be acquired to fund, in whole or in part,” the benefits. ...

3 March 2017 Internal T.I. 2016-0673661I7- Upstream loans – allocation of repayments Unedited CRA Tags 90(6); 90(8); 90(14) Principal Issues: Would the CRA follow the “first in, first out” method to allocate repayments in respect of multiple draws on a single credit facility? ... Marian Young HEADQUARTERS Senior International Auditor Income Tax Rulings International and Large Business Directorate Directorate International Tax Division Sylvain Grégoire International Advisory Services Section 2016-067366 Upstream loans – allocation of repayments This is in reply to your correspondence of October 26, 2016 in which you request our views on a particular aspect of the foreign affiliate upstream loan rules (the “Upstream Loan Rules”) contained in subsections 90(6) to (15). ...

TPS- Q & A Unedited CRA Tags 2 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. ... General Enquiries / Demandes de renseignements générales Q. I HAVE JUST RECEIVED AN ASSESSMENT OR REASSESSMENT NOTICE WITH A BALANCE OUTSTANDING. ...

24 October 1994 Internal T.I. 9420427- CAPITAL GAINS EXEMPTION & PERSONAL TRUSTS Unedited CRA Tags 110.6 104(21) 104(21.2) 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. ... Holloway Attention: Madeleine Chiasson (613) 957-2104 942042 Capital Gains Exemption & Personal Trusts This is in reply to your memorandum of August 9, 1994, requesting the clarification of the operation of the draft legislation in respect of the elimination of the $100,000 lifetime capital gains exemption as of February 22, 1994. ...

2 August 2001 External T.I. 2001-0085835- PUSH DOWN ACCOUNTING & LCT Unedited CRA Tags 181(3) 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. ... XXXXXXXXXX 2001-008583 August 2, 2001 Dear XXXXXXXXXX: Re: Push Down Accounting & Part I.3 Tax This is in your reply to your inquiry on the above noted subject addressed to the Sudbury Taxation Services Office, regarding a technical interpretation of the CCRA's position as described in paragraph 15 of IT-532. ...

13 December 2001 External T.I. 2001-0019525- Relationship between a trust & corporation Unedited CRA Tags 251(2) 256(7) 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. ... Fawcett & Son, Limited v. The Queen, 80 DTC 6195, no difference should be drawn between Mr. ...

13 May 2002 Internal T.I. 2002-0137727- MEALS & QUARTERS Unedited CRA Tags 6(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 CCRA. ... Vancouver Tax Services Office 613-957-8973 2002-013772 Taxability of Meals & Quarters Aboard a Ship in its Home Port We are writing in response to your inquiry of April 30, 2002, concerning a letter dated August 14, 1998 from the Canada Customs and Revenue Agency (CCRA) to the Department of Fisheries and Oceans (DFO) with respect to the above-noted issue. ...

28 February 2003 External T.I. 2002-0180945- HONORARIA & TRAVEL EXPENSE Unedited CRA Tags 6(1)(c) 6(1)(b)(vii.1) 81(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 613-957-8973 2002-018094 February 28, 2003 Dear XXXXXXXXXX: Re: Honoraria & Reimbursement of Travel Expenses We are writing in response to your letter of December 19, 2002, regarding a technical interpretation request on the above-noted issue, as it pertains to XXXXXXXXXX (the Committee). ...

19 February 2019 External T.I. 2018-0781651E5- Indian Employment Income – Guideline 4 Unedited CRA Tags 81(1)(a) Principal Issues: Whether employment income would be exempt from tax under Guideline 4 of the Indian Act Exemption for Employment Income Guidelines. ... XXXXXXXXXX 2018-078165 Michel Gauthier February 19, 2019 Dear XXXXXXXXXX: Re: Indian Employment Income – Guideline 4 This is in reply to your email dated October 10, 2018. ...