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La portion des honoraires facturés annuellement par la société à l'ensemble des clients qui est attribuable à l'occupation de l'espace de bureau représente plus de 50 % de l'ensemble des honoraires facturés. ...

(c) Paragraphs (b) and (c) of the "real estate investment trust" ("REIT") definition require that 95% / 75% of the trust's revenues for the taxation year be derived from rent from real or immovable properties etc. ...

In the past, corporations would assign expected refunds of SR & ED investment tax credits or Film Tax Credits as security for bridge financing for their operations. ...

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Yours truly, Daryl Boychuk Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Messore (613) 948-2227 2013-047410 November 20, 2014 Dear XXXXXXXXXX: Re: Paragraph 149(1)(l) of the Income Tax Act and capital gains This is in response to your email interpretation requests regarding a client ("entity ") that considers its income to be exempt from income tax pursuant to paragraph 149(1)(l) of the Income Tax Act. ...

Yours truly, Randy Hewlett Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Your view is that upon the declaration of the dividend by NRCo a "debtor – creditor" relationship arises between NRCo and the shareholder and as a result, in Scenario 1, the amount paid by NRCo to the shareholder after the Immigration Day should not be considered a dividend, but should rather be considered a payment to discharge the debt claim arising as a result of the declaration of the dividend. ...

For additional information on BIL, please see Interpretation bulletin IT-484R2, ARCHIVED – Business Investment Losses, on the CRA's web site. ...