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1 November 1991 External T.I. 91M11285 F- "Flow Through" of Deductions for Expenditures on SR & ED to Limited Partners Unedited CRA Tags 37 NOVEMBER 1991 QUESTION 16B Does section 37 permit the "flow through" of deductions for  expenditures on scientific research and experimental development to limited partners in a partnership which carries on a research business? ... BowenSection 31CCM # 912594 ...

22 November 1982 Income Tax Severed Letter RRRR63- Application of paragraph 95(2)(d) — merger of two United States foreign affiliates with United States parent who is a foreign affiliate Unedited CRA Tags 95(2)(d) XXX We reply to your letter dated August 10, 1982 wherein you request our opinion on the application of paragraph 95(2)(d) of the Income Tax Act in the case of a merger of two United States foreign affiliates with their United States parent who is also a foreign affiliate. ... We are pleased to advise that where there has been a bona fide merger of two United States foreign affiliates with their foreign affiliate United States parent paragraph 95(2)(d) of the Act will apply provided the other requirements of that paragraph are met viz "... and such merger is not as a result of the acquisition of property... ...

8 June 1987 Income Tax Severed Letter 7-1839- [Publication of Advance Income Tax Rulings # 3-0838] H.O. ... Brake June 8, 1987 Dear Sirs: Re: Publication of Advance Income Tax Rulings # 3-0838 Your letter of June 4, 1987 regarding the above-noted subject has been received and assigned to the Services, Public Utilities and Exempt Corporations Section for reply and may be identified by control number 7-1839. ...

15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares Unedited CRA Tags 39(2) Principal Issues: Whether our position announced at the 1999 TEI Conference and the 2000 CTF Conference regarding foreign exchange losses to the issuer corporation on redemption of its shares is still our position? ... MacMillan Bloedel, 99 DTC 5446 (FCA) January 15, 2007 Emidio De Angelis HEADQUARTERS Acting Banking Industry Specialist Income Tax Rulings Technical Applications & Valuations Division Directorate Montreal TSO S.E. ... Yours truly, Olli Laurikainen, Manager For Director International & Trusts Division Income Tax Rulings Directorate ...

12 December 1988 Income Tax Severed Letter 5-6777- [Scientific Research and Experimental Development ("SR & ED") "Non-Government Assistance"] M. Eisner (613) 957-2142 DEC 12 1988 Dear Sirs: Re: Scientific Research and Experimental Development ("SR & ED") "Non-Government Assistance" This is in reply to your letter of October 7, 1988 in which you asked us to reconsider a position set out in our letter to you dated September 28, 1988 wherein it was indicated that a taxpayer would not be entitled to an investment tax credit ("ITC") with respect to a reimbursement by virtue of paragraph 127(11.1)(c) of the Income Tax Act (the "Act"). This position was based on the concurrence that a reimbursement constituted non-government assistance as defined in subsection 127(9) of the Act in the following circumstances: a) A Canadian corporate taxpayer (Canco) incurs qualified SR & ED expenditures in Canada and owns all rights arising therefrom. b) A related non-resident corporation (NRCo) reimburses Canco for a portion of the qualified expenditures. ...

15 February 2021 Ministerial Correspondence 2021-0878041M4 F- Donation / Gift Unedited CRA Tags 3 Principales Questions: L’ARC doit-elle être informée d’une donation d’une somme d’argent au moyen d’un formulaire ou autrement? / Whether CRA need to be notified of a gift of money by form or otherwise of a gift of money? Position Adoptée: Dans la mesure où une transaction est une donation d’une somme d’argent qui ne peut pas être attribuée à une source productive de revenus, le seul fait de faire cette donation n’a pas à être divulgué à l’ARC au moyen d’un formulaire ou autrement. / To the extent that a transaction is a gift of money that cannot be attributed to a productive source of income, the mere fact of making that gift does not have to be disclosed to the CRA by means of a form or otherwise. ...

7 July 1991 Income Tax Severed Letter- Interest on loans — application of subparagraph 4(a) of Article 11 of the Canada-Netherlands Income Tax Convention Unedited CRA Tags 212(1)(b)(vii), Canada-Netherlands Income Tax Convension article 3, 11 Dear Sirs: This is in reply to your letter of May 8, 1991 in which you requested our views on the application of subparagraph 4(a) of Article 11 of the Canada-Netherlands Income Tax Convention (the "Convention"). ... The term "arm's length" is not defined in the Convention but paragraph 2 of Article 3 of the Convention provides that "... any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of the State concerning taxes to which the Convention applies. ... However, paragraph 251(1)(a) of the Act states that "... related persons shall be deemed not to deal with each other at arm's length". ...

1 February 1980 Income Tax Severed Letter 7-570- [] February 1, 1980 CALGARY DISTRICT OFFICE Chief of Audit Mr. ... Toyota (613) 995-1787 Section 125.1 Manufacturing & Processing Deduction ("MPD") This is in reply to your memorandum of January 10, 1980 requesting clarification of paragraph 34 of IT-145 as it relates to various items claimed by XXXX in determining its MPD in view of the St. ... Although fees paid for news services and talent fees (actors, etc.) may be related directly to qualified activities, they would not be included in the cost of M & P labour unless these functions were performed or normally performed by employees and the amounts are also included in the total cost of labour. ...

22 January 2013 External T.I. 2012-0445401E5- Eligible Dependent – Support by Court Order CRA Tags 118.5(b) Principal Issues: Does a father who is required to pay child support able to claim the eligible dependent, even when the court order so indicates? Position: No Reasons: Legislation & Court positions XXXXXXXXXX 2012-044540 George A. ... Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

A similar fact pattern was considered in CRA document # 2015-0622751I7 (August 16, 2017). ... (ii) This answer builds on the technical interpretation provided by the CRA in document # 2015-0622751I7 that was issued in 2017. ... Vicky Liu / Nicolas Bilodeau 2021-088752 May 5, 2021 ...