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15 January 2008 External T.I. 2007-0251591E5- Vested indefeasibly & change in trustees Unedited CRA Tags 108(1) 128.1 Principal Issues: General questions 1. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

8 October 2004 Roundtable, 2004-0086691C6- Rectification Orders & Annulment of Contracts Principal Issues: Whether the decision of the court in B.E.A. ... Trafsys Inc. and Trafsys Communications Inc changed the position of the CRA mentioned in Technical News # 22 with respect to rectification orders. ...

13 February 1998 Roundtable, E9731756- Subsection 20(12) & U.S. Social security tax20(12) 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. ... February 13, 1998 Jennifer Gilmour Enquiries & Adjustments David R. ...

13 June 1997 External T.I. 9715135- EXPENSES RELATING TO RRSP & RRIF Unedited CRA Tags 18(1)(u) 20(1)(bb) 146 146.3 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. ... Gillman Attention: XXXXXXXXXX June 13, 1997 Re: Administration Fees, Investment Counsel Fees: Registered Retirement Savings Plan ("RRSP") & Registered Retirement Income Funds ("RRIF") This is in reply to your letter of June 6, 1997, in which you ask us to clarify our position on the payment of the above-noted fees with respect to an RRSP and a RRIF. ...

19 September 1997 External T.I. 9722075- CHELATION THERAPY & PER KM RATE FOR MEDICAL TRAVEL Unedited CRA Tags 118.2(2)(h) 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. ... Principal Issues: chelation therapy and the cost related to medical travel by automobile that is not supported by receipts Position: cost of prescription drugs & fees to physician for chelation therapy qualify as a medical expense. ...

13 February 1998 Internal T.I. 9731756- Subsection 20(12) & U.S. ... February 13, 1998 Jennifer Gilmour Enquiries & Adjustments David R. ...

26 May 1998 External T.I. 9805745- SALARY / BONUS- REASONABLENESS Unedited CRA Tags 67 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. ... Principal Issues: Reasonableness of bonuses paid to shareholders / employees Position: As stated in question 42 of the 1981 Round Table (as clarified in Insights into the 1991 Revenue Canada Round Table Discussion), the Department will not challenge the reasonableness of salaries or bonuses paid to a principal shareholder who is active in the corporation’s business and the corporation has either established 1) a practice of distributing profits to such employee/shareholder in this manner, or 2) a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that in fact are attributable to special know-how or skills of the shareholder. ...

12 June 1998 External T.I. 9713925- AFFILIATED PERSONS, ESTATE, & STOP LOSS Unedited CRA Tags 164(6) 40(3.6) 112(3.2) 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 971392 Attention: XXXXXXXXXX June 12, 1998 Dear Sirs/ Mesdames: Re: Request for Technical Interpretations Subsections 164(6) and 104(19) of the Income Tax Act (the "Act “) This is in response to your letter of May 21, 1997 requesting a technical interpretation on the operation of subsections 164(6) and 104(19) to a particular fact situation. ...

28 July 1998 Internal T.I. 9816177- BED & BREAKFAST Unedited CRA Tags 18(12) 248(1) 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. ... Principal Issues: Whether subsection 18(12) applies in situation where two taxpayers operate a bed & breakfast in a house in which they reside? ...

5 June 1998 Internal T.I. 9805726- FUNDING ARRANGEMENTS-TENANTS & CHARITY Unedited CRA Tags 3 9 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. ... If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...