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7 March 1991 Income Tax Severed Letter- Reciprocal tax treaties — meaning of “periodic payment” Unedited CRA Tags none Subject: Reciprocal Tax Treaties Meaning of "Periodic Payment" This relates to our memorandum dated November 16, 1989 (copy attached), to which we received your interim reply dated February 14, 1991, and is further to the meeting of February 28 attended by the following: B. ...

7 February 1991 Income Tax Severed Letter- Research expenses — “...Current Nature” Unedited CRA Tags 37(2), 37(2)(c)(i) Subsection 37(2) and Subparagraph 37(7)(c)(i) of the Income Tax Act This is in response to the memorandum of February 4, 1991, prepared by F. ...

7 November 1991 Income Tax Severed Letter- Inventory write-down — single venture Unedited CRA Tags none QUESTION 49- INVENTORY WRITE-DOWN- SINGLE VENTURE QUESTION In light of the recent decision in Weatherhead v. ...

24 March 1980 Income Tax Severed Letter 5-1296- [] XXXX P.K. Tang 613-593-6201 March 24, 1980 Dear Sirs: Re: Section 125.1(3)(b) Manufacturing or Processing Deduction This is in reply to your letter of March 6, 1980 and our subsequent telephone conversation concerning the above-noted matter. ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares Unedited CRA Tags Subparagraph 2(c) of Article XXIX-A of the Canada-U.S. ... Reg. § 1.884-5(d)(4)(i)(B). Under the regulation, a class of shares is considered to be "regularly traded" if (i) trades of the class of shares are made in more than de minimis quantities on at least 60 days during the taxable year (hereafter the "de minimis test"), and (ii) the aggregate number of shares in the class traded during the year is at least 10 percent of the average number of outstanding shares during the year (hereafter the "10-percent test"). ...

13 November 2013 External T.I. 2012-0462421E5- CPP & EI tax credit CRA Tags 118.7 Principal Issues: Where an individual has been issued a T4 with employment income reported in error, can the CRA disallow the individual's CPP and EI tax credit claimed, after an amended T4 is issued? ... In computing this tax credit, paragraph 118.7(a) of the ITA states, in part, "…the total of all amounts each of which is an amount payable by the individual as an employee's premium for the year under the Employment Insurance Act, …" and paragraph 118.7(b) states, in part, "…the total of all amounts each of which is an amount payable by the individual for the year as an employee's contribution under the Canada Pension Plan…". ...

3 May 2016 CALU Roundtable Q. 5, 2016-0632641C6- Clearance certificate & GRE rules Principal Issues: Will the CRA clearance certificate process be modified in situations where a clearance certificate is needed before a gift can be completed by a graduated rate estate? ... CALU Roundtable – May 2016 Question 5- Clearance Certificates and GRE rules Background Subsection 159(2) of the Act requires a legal representative of a taxpayer to obtain a clearance certificate before distributing property under the legal representative’s control. ...

10 January 2011 External T.I. 2010-0365421E5- Maternity & Parental Leave for Self Employed Unedited CRA Tags 96(1); 103(1.1); paragraph 2 Partnership Act [RSBC 1996] Principal Issues: How does a general partner show no self-employed income from a [50/50] general partnership during the benefit period under the [new] initiative "Employment Insurance Benefits for Self-Employed People (EIBforSEP)"? ... Paragraph 2 of the Partnership Act [RSBC 1996] CHAPTER 348 defines Partnership as: "... the relation which subsists between persons carrying on business in common with a view of profit. ...

11 July 2007 External T.I. 2006-0216491E5- 75(2) & CCA limitation on rental income Unedited CRA Tags 1100(11)(a) Principal Issues: When 75(2) applies to attribute rental income earned by an alter ego trust to an individual who also earns income from rental properties owned by him directly, is the CCA limited to the rental income earned on all the property or are there separate CCA limitations for the property held by the alter ego trust and for the property held by the individual? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

29 June 2006 External T.I. 2006-0172341E5- Motor Vehicle Allowance & SBI Reimbursement Unedited CRA Tags 6(1)(b)(vii.1) 6(1)(b)(xi) 7306 (ITR) Principal Issues: Whether a reimbursement of an employee's supplementary business insurance (SBI) will render the payment of a motor vehicle allowance unreasonable for the purposes of subparagraph 6(1)(b)(vii.1) of the Act and cause the allowance to be a taxable benefit for the employee recipient. ... Yours truly, Randy Hewlett For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...