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Additionally a corporation with a “floating” year-end does not need to ask concurrence of the Minister under subsection 249.1(7) to be able to schedule a different year end each year – with the restriction that a fiscal period cannot exceed 53 weeks. ...

Although the tax treatment of a payment "..as consideration for a reduction in the rate of interest payable by a taxpayer on the debt obligation" is provided for under paragraph 18(9.1)(c) and subparagraph 18(9.1)(f)(i) of the Act, which applies " in the case of a reduction described in paragraph (c)... ...

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

(See case docket # A-242-99, September 13, 2000). It was unclear from the more recent remarks, however, whether the Agency's position has changed in light of the Federal Court of Appeal's confirmation of the Tax Court's decision. ...

Reasons: Question of fact and law XXXXXXXXXX 2012-043978 Lata Agarwal 613-957-8968 April 19, 2012 Dear XXXXXXXXXX: Re: “Specified employee” of a partnership This is in response to your email dated March 12, 2012, concerning your request for our views on the meaning of the term “specified employee” in subsection 248(1) of the Income Tax Act (“Act”) as it relates to expenditures in respect of Scientific Research & Experimental Development (“SR&ED”) under the Act. ...

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

File # 2001-011145 Prepared by Bill Kerr 957-3498 ...

As stated in paragraph 5 of the Interpretation Bulletin IT-285R2, Capital Cost Allowance – General Comments, generally, for a taxpayer to claim CCA on a property, the taxpayer must own the property. ...

Yours truly, Fiona Harrison, CPA, CA Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 "Regulations" means the Income Tax Regulations, C.R.C., c. 945, promulgated under the Act. ...

Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...