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Technical Interpretation - External

6 May 2003 External T.I. 2003-0014145 - Part XIII Fee for letter of credit

Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 2- ...
Technical Interpretation - External

25 April 2003 External T.I. 2002-0162855 - Powers of Appointment

Subsection 75(2) of the Act states in part: Where, by a trust created in any manner whatever since 1934, property is held on condition (a) that it or property substituted therefor may (i) revert to the person from whom the property or property for which it was substituted was directly or indirectly received (in this subsection referred to as "the person"), [...] ...
Technical Interpretation - External

26 June 2003 External T.I. 2003-0016735 - STATUS INDIAN RRSP FISHING INCOME

In our memorandum to the XXXXXXXXXX Tax Services Office (our file # 2003-001209 issued on June 10, 2003), we addressed your situation and provided our views regarding the taxation of your fishing income. ...
Technical Interpretation - External

27 June 2003 External T.I. 2002-0176265 - Holocaust victim assets litigation

., Manager for Division Director International & Trusts Division Income Tax Rulings Directorate- 4- ...
Technical Interpretation - External

16 December 2003 External T.I. 2002-0133665 - CONDITIONAL SALES AGREEMENTS

Our Comments The Canada Customs and Revenue Agency ("CCRA") announced in Income Tax Technical News No. 21, dated June 13, 2001, that: "... it is our view that the determination of whether a contract is a lease or a sale is based on the legal relationships created by the terms of the particular agreement, rather than on any attempt to ascertain the underlying economic reality. ...
Technical Interpretation - External

30 March 2004 External T.I. 2004-0061721E5 - Foster Care

We also acknowledge our subsequent telephone conversations (Young / XXXXXXXXXX). ...
Technical Interpretation - External

10 May 2004 External T.I. 2004-0060621E5 - Donation from an Alter Ego Trust

Lee Workman Financial Institutions Team Income Tax Rulings Directorate Policy & Planning Branch ...
Technical Interpretation - External

12 May 2004 External T.I. 2004-0065281E5 - Subsection 20(8)

We also acknowledge our telephone conversations (Young / XXXXXXXXXX) of May 4 and 5, 2004. ...
Technical Interpretation - External

20 May 2004 External T.I. 2003-0042681E5 - assignment of insurance to EFA under 148.1

Theresa Murphy Manager Trust Section International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Technical Interpretation - External

22 June 2004 External T.I. 2004-0069801E5 - Gift - Expenses incurred by a donor

Lee Workman Financial Institutions Team Income Tax Rulings Directorate Policy & Planning Branch ...

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