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Chief- Engineering, Technical & Research Team Industrial Programs Division Office of Energy Efficiency 580 Booth St., 18th Floor Ottawa ON K1A 0E4 ...

Our Comments Question 1 The northern residents deduction under paragraph 110.7(1)(a) of the Act is computed by multiplying a specified percentage by " an amount received, or the value of a benefit received or enjoyed, in the year by the taxpayer in respect of the taxpayer's employment in the particular area by a person with whom the taxpayer was dealing at arm's length in respect of travel expenses incurred by the taxpayer or another individual who was a member of the taxpayer's household during the part of the year in which the taxpayer resided in the particular area. ...

We are enclosing the pamphlet entitled “Electing Under Section 217 of the Income Tax Act ” plus the guide entitled “Genera Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada 2000”. ...

However, we do recognize that there is a possibility of double taxation in some situations, and, as we have previously stated (see, for example, the attached excerpt from Income Tax Technical News), we are willing- in the context of an advance income tax ruling, where all relevant facts are available – to consider applying the law so that double taxation is avoided. ...

Paragraph 3(d) of Article XI of the Convention, as it read prior to the Third Protocol, was worded as follows: "the interest is beneficially owned by a seller who is a resident of the other Contracting State and is paid by a purchaser in connection with the sale on credit of any equipment, merchandise or services, except where the sale is made between persons dealing with each other not at arm's length;" (underlining for emphasis) Paragraph 3(d) of Article XI of the Convention was amended by the Third Protocol and currently reads as follows: "the interest is beneficially owned by a resident of the other Contracting State and is paid with respect to indebtedness arising as a consequence of the sale on credit by a resident of that other State of any equipment, merchandise or services except where the sale or indebtedness was between related persons;" (underlining for emphasis) The Technical Explanation to the Third Protocol, as it pertains to paragraph 3(d) of Article XI of the Convention, reads, in part, as follows: "...... ...

De plus, l'employé n'a pas droit au montant supplémentaire de 1 500 $ prévu à 60j.1)(ii)(B) à l'égard des années de service rachetées. ...

Reasons FOR POSITION TAKEN: Consistent with previously published positions (file # 9609563 and E9M19190). ...

In Young, a Tax Court of Canada case (86 DTC 1567), the Court considered the income tax consequences of a taxpayer who was awarded damages by Court Order in the following amounts: $10,000.00 for wrongful dismissal $12,500.00 for exemplary damages $12,500.00 for mental distress $ 5,000.00 for costs The taxpayer Appellant did not include the damages for mental distress and the exemplary damages in computing his income. ...

The value of the investments has increased considerably since they were acquired and now represents more than 50 % of the fair market value (FMV) of all of OPCO II's assets. ...

To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office ("TSO") of the Canada Customs & Revenue Agency (the "CCRA"). ...