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Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Since your inquiry relates to a specific proposal to establish an actual arrangement, written confirmation of the tax implications may only be provided by us where the proposal is the subject matter of an advance income tax ruling request submitted in the manner set out in the Canada Customs & Revenue Agency's (the "Agency") Information Circular IC70-6R3 Advance Income Tax Rulings which may be obtained from your local tax services office or on the Internet at http://www.ccra-adrc.gc.ca/menu-e.html. ...

In our view, Guidelines 1, 2 & 3 will not apply to exempt your employment income, as you resided off-reserve and less that 50% of your duties of employment were performed on reserve. ...

Basically, "weekly rate of pay" was changed to mean an employee's annual rate of pay divided by 52.176 plus annual amounts of FSD 55, 56, & 58 to which she would have been entitled had she not been on maternity leave without pay divided by 52.176. ...

Parnanzone Attention: Karen Clarke March 20, 2000 Dear Sir/Madam: Re: XXXXXXXXXX Entitlement to the Status Indian Exemption This is in reply to your memorandum of August 18, 1999, enquiring whether XXXXXXXXXX (the " Employee"), a status Indian, is exempt from income taxation on her benefits under the Employment Insurance Act. ...

Debts issued by the following entities would qualify as qualified investments: (a) bonds, debentures, notes or similar obligations of a corporation the shares of which are listed on a prescribed stock exchange in Canada (prescribed stock exchanges in Canada are listed in section 3200 of the Regulations); (b) bonds, debentures, notes, mortgages or similar obligations (i) of or guaranteed by the Government of Canada; (ii) of the government of a province or an agent thereof; (iii) of a municipality in Canada or a municipal or public body performing a function of government in Canada; (iv) of a corporation, commission or association not less than 90% of the shares or capital of which is owned by Her Majesty in right of a province or by a Canadian municipality, or of a subsidiary wholly-owned corporation that is a subsidiary to such corporation, commission or association; (v) of an education institution or a hospital if repayment of the principal amount thereof and payment of the interest thereon is to be made, guaranteed, assured or otherwise specifically provided for or secured by the government of a province; (c) guaranteed investment certificates issued by a trust company incorporated under the laws of Canada or of a province; (d) a bond, debenture, note or similar obligation of a public corporation other than a mortgage investment corporation; (e) a bond, debenture, note or similar obligation issued by a mutual fund trust the units of which are listed on a prescribed stock exchange in Canada; (f) a bond, debenture, note or similar obligation issued by a credit union that meets certain conditions described in paragraph 4900(1)(g) of the Regulations; (g) a bond, debenture, note or similar obligation issued by a cooperative corporation that meets certain conditions described in paragraph 4900(1)(h) of the Regulations; (h) a bond, debenture, note or similar obligation issued by a Canadian corporation where the debt is guaranteed by a corporation or mutual fund trust that is listed on a prescribed stock exchange in Canada; or where the corporation is controlled by a corporation and / or mutual fund trust that is listed on a prescribed stock exchange in Canada; or where the corporation has issued at least $10 million bonds, debentures, notes or similar obligation, and meets certain other requirements as described in paragraph 4900(1)(i) of the Regulations; (i) a security of a Canadian corporation issued pursuant to certain community development acts and guaranteed by Her Majesty in right of a province, as set out in paragraph 4900(1)(i.1) of the Regulations; (j) indebtedness of a Canadian corporation (other than a corporation that does not deal at arm's length with a person who is an annuitant, a beneficiary or an employer under the governing plan trust) represented by a bankers' acceptance; (k) a mortgage in respect of real property situated in Canada as set out in paragraph 4900(1)(j) or subsection 4900(4) of the Regulations; (l) a bond, debenture, note or similar obligation issued or guaranteed by a certain international development banks listed in paragraph 4900(1)(l) of the Regulations; (m) a bond, debenture, note or similar obligation issued by a government of a country other than Canada that had, at the time of purchase, an investment rating with a bond rating agency that in the ordinary course of its business rates the debt obligations issued by that government; (n) bonds, debentures, notes or similar obligations of a corporation the shares of which are listed on a prescribed stock exchange outside of Canada (prescribed stock exchanges outside of Canada are listed in section 3201 of the Regulations); (o) a debt issued by a Canadian corporation (other than a corporation with share capital or a corporation that does not deal at arm's length with a person who is an annuitant, a beneficiary or an employer under the governing plan of the plan trust) if (i) the taxable income of the corporation is exempt from tax under Part I of the Act because of paragraph 149(1)(l) of the Act (i.e., a club, society or association that meets certain conditions and that, in the opinion of the Minister, was not a charity within the meaning assigned by subsection 149.1(1) of the Act); and (ii) either the debt is issued by the corporation as part of an issue of debt by the corporation for an amount of at least $25 million or, at the time of the acquisition of the debt by the plan trust, the corporation had issued debt as part of a single issue for an amount of at least $25 million; or (p) debt of a corporation as described in (o)(i) above, and the corporation has acquired or plans to acquire property from Her Majesty in right of Canada or a province for a total consideration of not less than $25 million, and that meets certain other requirements as set out in paragraph 4900(1)(q) of the Regulations. ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Please note that our file # 9911687, on which you have based much of your opinion, contained a typo in the second sentence of the fourth paragraph of the comments section. ...