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Yours truly, for Director Reorganizations and International Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...

., Ottawa, K1A 0H2, facsimile # (613) 952-8219. A non-resident corporation that carries on business in Canada would be subject to tax in Canada pursuant to Part I of the Income Tax Act (the "Act"). ...

Reasons: 1 & 2 Our understanding and reading of 53(2)(c)(i) and 96(2.5), respectively. 972714 XXXXXXXXXX Allan Nelson (613) 957-9768 Attn. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate ...

Lee Workman Manager Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch?? ...

This may result in inconsistancies since some individuals will request the certification before death and others will not be aware of the need to ask for a certification until after death & it would be difficult to argue that a disability is expected to last more than 12 months if the patient has already died before the 12 month period has elapsed. ...

Reasons: Subsection 147(20) & (19) and 146(16) of the Act permit the transfer. ...

Le bulletin d’interprétation IT-430R3 et les Nouvelles techniques # 10 traitent des conséquences fiscales pour une société privée lorsqu’une police d’assurance-vie est utilisée pour garantir une dette. ...

Principal Issues: health spending accounts- expenses incurred prior to participation in the plan Position: a plan which reimburses such expenses is not a plan of insurance & thus not a PHSP Reasons: can be distinguished from a plan which does provide insurance but permits the carry-forward of expenses in excess of annual ceiling limits 973032 XXXXXXXXXX A. ...