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Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – XXXXXXXXXX ...

Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – XXXXXXXXXX ...

Yours truly, Kimberley Wharram Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Appendix A – Mining Claims List XXXXXXXXXX ...

Paragraphs 6(a) and 6(b) of IT-497R are derived from clauses 122.3(1)(b)(i)(A) and (B) of the Act respectively which cover: (A) the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources, (B) any construction, installation, agricultural or engineering activity, or … Section 255 of the Act reads: For the purposes of this Act, "Canada" is hereby declared to include and to have always included (a) The sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the Government of Canada or of a province grants a right, licence or privilege to explore for, drill for or take any minerals, petroleum, natural gas or any related hydrocarbons; and (b) The seas and airspace above the submarine areas referred to in paragraph (a) in respect of any activities carried on in connection with the exploration for or exploitation of the minerals, petroleum, natural gas or hydrocarbons referred to in that paragraph. ... For clarity, under section 18 of the Oceans Act: Canada has sovereign rights over the continental shelf of Canada for the purpose of exploring it and exploiting the mineral and other non-living natural resources of the seabed and subsoil of the continental shelf of Canada, … In section 17 of the Oceans Act, the continental shelf is defined as follows: 17(1) The continental shelf of Canada is the seabed and subsoil of the submarine areas, including those of the exclusive economic zone of Canada, that extend beyond the territorial sea of Canada throughout the natural prolongation of the land territory of Canada (a) subject to paragraphs (b) and (c), to the outer edge of the continental margin, determined in the manner under international law that results in the maximum extent of the continental shelf of Canada, the outer edge of the continental margin being the submerged prolongation of the land mass of Canada consisting of the seabed and subsoil of the shelf, the slope and the rise, but not including the deep ocean floor with its oceanic ridges or its subsoil; (b) to a distance of 200 nautical miles from the baselines of the territorial sea of Canada where the outer edge of the continental margin does not extend up to that distance; or (c) in respect of a portion of the continental shelf of Canada for which geographical coordinates of points have been prescribed pursuant to subparagraph 25(a)(iii), to lines determined from the geographical coordinates of points so prescribed. ...

Information contained in the GST/HST Rulings Directorate interpretation indicated that you had previously reported and filed the estate trustee fees as "Other income" under "Part 3 – Gross business or professional income" on Form T2125, Statement of Business or Professional Activities. ... More information on payroll deductions and remittances can be found in the Canada Revenue Agency guide T4001, Employer's Guide – Payroll Deductions and Remittances at http://www.cra-arc.gc.ca/E/pub/tg/t4001/t4001-13e.pdf The trustee fees earned in the course of business form part of the business income of the estate trustee under subsection 9(1) of the Act. ...

Section 84.1 of the Act would achieve that result either: • by reducing the paid-up capital of the shares of Holdco received by you and your wife in consideration for the Corporation shares (this reduction reduces the ability to return paid-up capital of Holdco, which is basically the legal stated capital of the shares adjusted for tax purposes, as the excess would be taxed as a dividend); • by deeming you and your wife to have received a dividend where Holdco gives non-share consideration for the Corporation shares (for example, cash or a promissory note). ...

Question of fact. 2, 3, & 4: No. Will depend on the facts of each case. ... & 4. A change in an employee's manager does not impact whether a particular work site can be considered a special work site under subsection 6(6) of the Act. ...

17 May 2010 External T.I. 2009-0343551E5- Specified energy property- partnership Unedited CRA Tags 1100(24)- (29); Class 43.1 / 43.2 Principal Issues: Can a partnership claim CCA on the cost of depreciable property that is a rooftop photovoltaic system acquired by the partnership to generate electricity that is sold to the Ontario Power Authority pursuant to the Feed-In Tariff Program? ... As discussed with you on April 15, 2010 (Naufal / XXXXXXXXXX), we are unable to issue an advance income tax ruling as requested in your letter. ...

17 May 2010 External T.I. 2009-0341721E5- Specified Energy Property Unedited CRA Tags 1100(24)- (29); Class 43.1 / 43.2 Principal Issues: Whether the specified energy property provisions would apply to restrict CCA in a situation where a taxpayer acquired a photovoltaic system to generate electricity which is sold to the Ontario Power Authority under the Standard Offer Program. ... Background As discussed with you (Naufal / XXXXXXXXXX), please be advised that that the RESOP was replaced, in 2009, by the Feed-In Tariff ("FIT") and microFIT Programs that were introduced pursuant to Ontario's Green Energy Act, 2009 and administered by the OPA. ...

Furthermore, prior to 2001, the definition of the term "business agency" read: " 'business agency', of a congregation at any time in a particular calendar year, means (a) a corporation... where the congregation owned all the shares of the capital stock of the corporation (except directors' qualifying shares)... or (b) a corporation... of which the congregation (i) has effective management or control throughout the portion of the particular year throughout which both the congregation and the corporation... were in existence, and (ii) had effective management or control during a taxation year of the corporation... that began before March 1999 and ended in the particular year;... ... Transfer of Property as Dividend in Kind Our document 9617155 states that: "... income earned by the Corporation will be income of the trust and not income or surplus of the Corporation. ...