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

Reasons: IT-339 & definition of PHSP under subsection 248(1) XXXXXXXXXX 2009-035158 Rob Ferrari February 17, 2010 Dear XXXXXXXXXX: Re: Taxable Benefits- Private Health Services Plan We are writing in response to your fax of October 14, 2009 regarding an employer's health and wellness plan (the "Plan"). ...

Yours truly, Nerill Thomas-Wilkinson Acting Manager For Acting Director Ontario Corporate Tax Division 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 ...

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

Thomson For Director International & Trusts Division Income Tax Rulings Directorate ...

However, as stated in our document # 2002-0165325, it is our view that where the MIC provides services to tenants of a rental property that the MIC has acquired, or develops the property while the property is held for resale, the MIC would be considered to be managing or developing real property for the purposes of paragraph 130.1(6)(b). ...

For the purposes of paragraph 149(1)(d.5) and subsection 149(1.2) of the Act, subsection 149(1.3) of the Act provides that 90% of the capital of a corporation that has issued share capital will not be considered to be owned by one or more municipalities unless the municipalities are also entitled to at least 90% of the votes that would be cast under all circumstances at an annual meeting of shareholders of the corporation (see our document # 2001-0114125). ...

We understand that XXXXXXXXXX gave the money raised to a registered charity affiliated with the XXXXXXXXXX, the "XXXXXXXXXX ", who in turn gave the money to the XXXXXXXXXX to cover the players' training fees. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...