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Principal Issues: Whether reimbursement of tuition fees would fall within the guidelines set out in ITTN 13 when the fees are XXXXXXXXXX % reimbursed after the employee has been with the employer for XXXXXXXXXX years following the course, and fully reimbursed after XXXXXXXXXX years.. ...

In addition to Interpretation Bulletin IT-419R, we have enclosed for your reference, CCRA Guide number RC 4108(E) "Registered Charities and the Income Tax Act ". ...

Principal Issues: 2002 Canadian Tax Foundation Q & A regarding the Exchange of Property Rules and Business Expansions. ...

As stated in Oosterhoff's Text Commentary & Cases on Trusts, an instrument which purports to grant a power of appointment may be construed as creating a discretionary trust, a power of appointment or an outright gift. ...

On behalf of the Canada Customs & Revenue Agency ("CCRA"), we apologize for the delay in responding to your inquiry. ...

The Canada Customs and Revenue Agency administratively accepts that the amount of the superficial loss may be determined by using the following algebraic formula: SL = (Least of S, P and B)/S x L where SL is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 61-day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...

Scenario 2: Items 1 & 2 are the same as in scenario 1 above. 3. Mr. ...

Principal Issues: Treatment of proceeds of sale / transfer of guiding and outfitting licenses. ...

Whether "communication cable, including riser cable" is included in Class 1, Class 3, Class 8 or Class 10 " is a question of fact and can only be determined by reviewing an actual usage of such cable. ...

Income Tax Convention (the " Convention") or for purposes of the Income Tax Act (the "Act"). ...