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In your letter, you state that you care for mentally and / or physically disabled children and adults in your home. ...

". If a payment is not an "income or profits tax", it is not eligible for a tax credit pursuant to subsection 126(2) of the Act, but it is deductible from the income of the business pursuant to paragraph 18(1)(a) of the Act if it is incurred for the purpose of gaining or producing income from the business. ...

& 3. In the event the competent authorities of Canada and the U.S. agree that a particular trust is considered to be a resident of the U.S. and not a resident of Canada for the purpose of the Treaty, subsection 250(5) would apply to deem that trust not to be resident in Canada for any purpose of the Act. ...

You state in your letter that you have spoken to the Canada Custom & Revenue Agency (the "CCRA") XXXXXXXXXX Tax Services Office (TSO) (XXXXXXXXXX) regarding the matter. ...

However, the qualifying income shall be computed without "any portion of income that was deductible under subparagraph 110(1)(f)(i) [... or] under section 110.6", or without any "tax-exempt income". ...

As stated in paragraph 9 of IT-215R " In order that an expense which is unpaid at the end of a taxation year may be deductible for tax purposes, the liability so created in respect of that expense must constitute a genuine liability of that taxpayer in that taxation year. ...

Reasons: 1) & 2) Wording of the Act XXXXXXXXXX 2003-002965 Shaun Harkin, CMA October 20, 2003 Dear XXXXXXXXXX: Re: Technical Interpretation Request: Tax Treatment of Partnership Interest This is in reply to your letter of July 8, 2003 wherein you asked for our comments in respect of the following hypothetical situation:? ...

Yours truly, Jim Wilson for Director International & Trusts Division Income Tax Rulings Directorate- 3- ...

Other Comments Pursuant to paragraph (g.1) of the definition of "Canadian exploration expense" ("CEE") in subsection 66.1(6) of the Income Tax Act (the "Act"), expenses incurred by a taxpayer that qualify for inclusion in "Canadian renewable and conservation expense" (" CRCE", as defined in the above subsection of the Act) will also be included in the taxpayer's CEE. ...

., states as follows: "--- I would add only this: the Income Tax Act, read as a whole, envisages that a distribution of corporate surplus to shareholders is to be taxed as a payment of dividends. ...