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We also acknowledge our telephone conversation (Young / XXXXXXXXXX) of February 2 and 26, 2015. ...

Ouimet, CPA, CA November 7, 2014 Dear XXXXXXXXXX: Subject: Refund of Part XIII tax when PLOI election is late-filed We are writing in response to a question you posed during our telephone conversation (Young / XXXXXXXXXX) on August 5, 2014, which was a follow-up to our technical interpretation 2014-051943. ...

For additional information on debt obligations that are qualified investments, you may refer to paragraph 10 of Income tax interpretation bulletin (IT)-320R3, "Qualified Investments – trusts governed by registered retirement savings plans, registered education savings plans and registered retirement income funds". ...

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

21 October 2013 External T.I. 2013-0477121E5- FTC and US Expat Regime CRA Tags 20(12) 20(11) Treaties Article XVIII 126 Treaties Article XXIX Principal Issues: Does the interaction of section 126 and Article XVIII(2) and Article XXIX(2) of the Canada / US Tax Treaty limit the taxpayer's foreign tax credit claim in respect of his periodic pension payments arising in the US in the particular circumstances? ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Manager International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

In The Queen et al v Addison & Leyen Ltd. Et al 2007 SCC 33 it was established that there is no limitation period for when the Minister can issue an assessment under section 160 of the Act. ...

Therefore, the value of the service is included in the individual’s income under subparagraph 56(1)(r)(iii) of the Act where the program meets each requirement described in (A) – (C) above. ...

Moore for Director Partnerships & Corporate Financing Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...