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. * Similar arrangements may be offered to other First Nations under self-government agreements or arrangements, but thus far the Yukon arrangements are the only ones that have been implemented regarding income tax. * (Some "GST-style" sales tax arrangements have also been implemented with a number of other First Nations.) * Further questions about such initiatives should be directed to the Department of Finance. * Note that the 2000 Federal Budget repeated the "offer" from previous years, to discuss and put into effect arrangements in respect of direct taxation with interested First Nations. ...

Subclause (d)(vii) of Class 43.1 Subparagraph (d)(vii) of Class 43.1 reads as follows: and property, other than reconditioned or remanufactured equipment, that would otherwise be included in another Class in this Schedule (d) that is … (vii) equipment used by the taxpayer, or by a lessee of the taxpayer, primarily for the purpose of generating electrical energy solely from geothermal energy, including such equipment that consists of piping (including above or below ground piping and the cost of drilling a well, or trenching, for the purpose of installing that piping), pumps, heat exchangers, steam separators, electrical generating equipment and ancillary equipment used to collect the geothermal heat, but not including buildings, transmission equipment, distribution equipment, equipment designed to store electrical energy, property otherwise included in Class 10 and property that would be included in Class 17 if that Class were read without reference to its subparagraph (a.1)(i), Subparagraph (d)(vii) of Class 43.1 requires that the equipment be used by the taxpayer, or by a lessee of the taxpayer, primarily for the purpose of generating electrical energy solely from geothermal energy. ... Paragraph (p) of Class 1 applies to a distributor of heat: Property not included in any other class that is … (p) the production and distributing equipment and plant (including structures) of a distributor of heat; Paragraph (q) of Class 1 applies to a producer or distributor of geothermal energy: Property not included in any other class that is … (q) a building or other structure, or a part of it, including any component parts such as electric wiring, plumbing, sprinkler systems, air-conditioning equipment, heating equipment, lighting fixtures, elevators and escalators (except property described in any of paragraph (k) and (m) to (p) of this Class or in any of paragraphs (a) to (e) of Class 8). ... Guide T100 – Instructions for the Flow-Through Share Program, provides information on reporting procedures regarding the flow-through share program. ...

Position: Scenario 1, 2 & 3: Question of fact. Scenario 4: Question of fact but likely yes. Reasons: Scenario 1, 2 & 3: Overview of relevant Treaty Articles provided. ... Yours truly, Lita Krantz for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

2 March 2005 External T.I. 2004-0084891E5- Securities lending arrangement Unedited CRA Tags 260(1)(c) 260(5) & (6) 260(8) Principal Issues: (a) Does CRA interpret the words in paragraph 260(1)(c) of the definition of a "securities lending arrangement" ("Definition") as meaning that a borrower of a qualifying security must have disposed of the security before a dividend is paid by the issuer in order to meet the dividend compensation payment criteria in the said paragraph? ... (c) That CRA confirm your understanding of our technical interpretation letter (our file # 2001-0087365) which sets out our views on lending arrangements under a short sale agreement to which section 260 of the Act does not apply ("non-qualifying lending arrangements"). In particular, technical interpretation letter # 2001-0087365, dated September 11, 2001 (the "Technical Interpretation") states the following: It is the Agency's position that the transfer of the securities by the lender to the borrower, under a short sale arrangement to which section 260 of the Act does not apply, generally results in a disposition of the securities by the lender at fair market value and an acquisition by the borrower at fair market value on the date the securities are transferred to the borrower. ...

As mentioned in previous technical interpretations, subsection 75(2) of the Act might apply notwithstanding the fact that the property is transferred to the trust at fair market value or that the person from whom the property was received by the trust has the right to reacquire it at its fair market value (see documents # F 9330085, E 9218450 and E 2000-0012557 and APFF 1994 Round Table, Question 24). ... In other words, subsection 107(4.1) of the Act does not require that subsection 75(2) be applicable at the time of the distribution but only that it was applicable at any time in respect of any property of the trust (see documents # E 2001-0067955 and E 2001-00955511). ... Comments Pursuant to subsection 75(2) of the Act, any income, including deemed dividends, from a property which is held by a trust under one or more of the conditions described in paragraphs 75(2)(a) or (b) is deemed to be income of the person from whom the property was received by the trust (see document # 73808). ...

/ Whether the CCRA is ready to announce policies on e-commerce, particularly in regard to permanent establishment and realization of income. Position Adoptée: Non. / No. Raisons POUR POSITION ADOPTÉE: Différents groupes consultatifs techniques poursuivent encore leurs travaux et l'OCDE souhaite qu'un certain consensus international soit atteint avant qu'une initiative importante soit prise au niveau national. / Different technical advisory groups pursue their study and the OECD wishes that a joint international position be achieved before any major initiative be undertaken on the national level. ...

/ What are the tax consequences for canadian shareholders of the spin-off of XXXXXXXXXX? Position Adoptée: Commentaires généraux concernant l'article 86.1 proposé de la Loi. / General comments provided on proposed section 86.1 of the Act. Raisons POUR POSITION ADOPTÉE: Question de droit et de fait. / Question of law and of fact. ...

Yours truly, Olli Laurikainen Manager International Section II Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Yours truly, Daryl Boychuk for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

In this regard, reference may be made to paragraph 10 of IT-464R, Capital Cost Allowance – Leasehold Interests. ...