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Position: YES Reasons: IT-522 par 9, fairness for cash basis employees who cannot use 18(9) to average out the up-front deduction, provided amount meets the 67.3 limitation if amount is averaged out and vehicle is within the other restrictions of the section ie $ 30,000 vehicle cost and $800 mo. lease. 2003-005179 XXXXXXXXXX C. ...

Lee Workman Financial Institutions Team Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...

Lee Workman Financial Institutions Team Income Tax Rulings Directorate Policy & Planning Branch c.c.: Denis Normand Department of Finance ...

In your letter you also refer to a prior rulings document # 2002-0132427 ("prior position") wherein we had expressed the view that in similar circumstances a payer corporation's RDTOH would still be reduced pursuant to paragraph 129(3)(d). ...

Il nous apparaît que dans la situation ci-dessus où les actionnaires choisissent de recevoir seulement des actions ordinaires de PUBLICO, le produit de disposition serait de 10 $ pour chaque action de OPCO. ...

This handbook is referenced as document # 94-110 and can be found in the Miscellaneous Information Returns section in the Other Information Returns window of the website. ...

OUR COMMENTS We agree with your analysis that the calculation of X Co's taxable capital gain pursuant to the formula in subsection 96(1.7) is as follows: A x B = $37.50 x 1/2= $25 C 3/4 Where the inclusion rate in A is 3/4 as a result of the deeming rule in 38(i) of the Act the inclusion rate in B is 1/2 [the rationale is that subparagraph (d) of the coming into force provision for the amendments made to paragraph 38(1) in 2001, c.17, s.22 do not apply to this situation, since subsection 96(1) of the Act provides for an allocation of the taxable capital gain of the Partnership for its fiscal period ending December 31, 2000 to X Co in its taxation year ending April 30, 2001]. the inclusion rate in C is 3/4, which is the inclusion rate used for the Partnership. ...

" The words " in respect of" were considered in the Supreme Court of Canada decision Nowegijick v. ...

Yours truly, Roberta Albert, CA for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

In your letter, you requested clarification of our comments regarding the potential application of the general anti-avoidance rule ("GAAR") found in section 245 of the Income Tax Act ("the Act") that appeared in technical interpretation # 1999-0008945 as they may apply to a situation described in your letter. ...