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Technical Interpretation - External

4 March 2011 External T.I. 2011-0393351E5 - Settlement

(See also 11). Two questions set out by the Courts to determine whether a connection exists for purposes of a retiring allowance are as follows: 1- But for the loss of employment would the amount have been received? ...
Technical Interpretation - External

21 February 2011 External T.I. 2011-0394051E5 - Wind Turbines and ITCs

Pursuant to subsection 4600(2) of the Regulations a property is "prescribed machinery and equipment" if, inter alia, it is depreciable property of the taxpayer that is: "..... ...
Technical Interpretation - External

7 April 2010 External T.I. 2009-0322651E5 - Moving Expenses - GST Paid

Yours truly, Jenie Leigh Manager For Acting Director Ontario Corporate Tax Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External

12 April 2010 External T.I. 2010-0359501E5 - Employee Birthday Gifts

Further details as to the qualifying nature of gifts and awards may be found on the CRA's website at: http://www.cra-arc.gc.ca/tx/bsnss/tpcs/pyrll/bnfts/gfts/menu-eng.html ". ...
Technical Interpretation - External

2 December 2010 External T.I. 2010-0384102E5 - Withholding on Wrongful Dismissal Settlement

You have stated that your former Ontario employer withheld XXXXXXXXXX % from a termination amount of $XXXXXXXXXX. ...
Technical Interpretation - External

29 September 2010 External T.I. 2010-0379521E5 - Allowance for Paramedics

In order for a meal or other travel allowance to be exempted by the policy in ITTN # 40 it is also a requirement that the allowance be paid primarily to benefit the Employer. ...
Technical Interpretation - External

10 March 2011 External T.I. 2011-0397511E5 - Withholding Requirements for Non-resident Employee

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

14 March 2011 External T.I. 2011-0395271E5 - Reserve for quadrennial survey

Subsection 20(1) reads as follows: "Deductions permitted in computing income from business or property- Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:" Paragraph 20(1)(o) of the Act, which permits a taxpayer to claim a reserve for quadrennial survey, reads as follows: "..... such amount as may be prescribed as a reserve for expenses to be incurred by the taxpayer by reason of quadrennial or other special surveys required under the Canada Shipping Act...... ...
Technical Interpretation - External

24 March 2010 External T.I. 2010-0360061E5 - Residency Status - OHIP usage

OHIP Concerning your client's wish to reimburse Ontario's Ministry of Health & Long-Term Care for the medical expenses that were covered under OHIP (i.e., that you acknowledge should not have been), it has been suggested to us by an OHIP agent that your client may contact that Ministry by phone (at 1-888-781-5556) and/or by email (at reportohipfraud@moh.gov.on.ca) to make arrangements to reimburse the expenses. ...
Technical Interpretation - External

23 June 2010 External T.I. 2010-0369581E5 - Allocation of Partnership Income

23 June 2010 External T.I. 2010-0369581E5- Allocation of Partnership Income Unedited CRA Tags 12(1)(l);96; 103(1.1) Principal Issues: Is the full allocation of income earned from a husband / wife farming partnership to one spouse acceptable during a period in which the other spouse takes maternity leave from the business operations of the partnership and contributes no labour? ...

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