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Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

In two separate technical interpretations (see 9112095 and 9708635), the Income Tax Rulings & Interpretations Directorate of Revenue Canada opined that a partnership can be a party to a section 16.1 election as either a lessee or a lessor. ...

The prizes and awards (hereinafter referred to as "awards") for which you have requested our views are as follows: (1) Governor General's Literary Award (13) Governor General's Award in Visual & Media Arts (2) Canada-Japan Literary Award (14) Izaak Walton Killam Memorial Prize (3) Healey Willan Prize for Amateur Choirs (15) Canada Council Grand Prize for CBC Young Composers Competition (4) Canada Council for the Arts Molson Prize (16) Canada Council/CBC First Prize for CBC Young Performers Competition (5) Glenn Gould Prize (17) Virginia Parker Prize (6) Bell Canada Award in Video Art (18) Jean Marie Beaudet Award (7) John Hirsch Prize (19) Sylva Gelber Foundation Award (8) Petro-Canada Award for New Media (20) Robert Fleming Prize (9) Jules Léger Prize for New Chamber Music (21) Duke and Duchess of York Prize in Photography (10) Jacqueline Lemieux Prize (22) Joseph S. ...

Limitation of liability The effect of registration as an LLP is set out in subsection 11.1(1) of the Alberta Partnership Act which states: "... a partner in an Alberta LLP is not individually liable directly or indirectly, by means of indemnification, contribution, assessment or otherwise, for debts, obligations or liabilities of the partnership or another partner that arise from the negligence, wrongful acts or omissions, malpractice or misconduct of (a) another partner, or (b) an employee, agent or representative of the partnership, that occur in the ordinary course of carrying on practice in an eligible profession within the meaning of section 79.1 while the partnership is an Alberta LLP. ...

Interpretation Bulletin IT-91R4 "Employment at Special or Remote Work Locations" explains the terms "remote work location " and "special work site" and provides further details concerning the criteria for these exemptions. ...

Yours truly, Kimberley Wharram Acting Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 For the present purposes, the word “primarily” means more than 50%. 2 C.R.C. c. 945, as amended. 3 R.S.C. 1985, c. 1 (5th suppl.) as amended. 4 The following property only qualifies for an inclusion in Class 43.1: (i) mid-efficiency, fully or partially fossil-fuelled cogeneration systems; (ii) electric vehicle charging stations set up to supply more than 10 kW but less than 90 kW of continuous power; and (iii) electrical energy storage equipment connected to one of the above systems and stand-alone electrical energy storage systems meeting particular efficiency requirements. 5 See paragraphs (b) and (e) of Class 43.1. 6 During the phase-out period the enhanced CCA rates are as follows: for eligible properties that are available for use in: 2024 and 2025 the rate is 75%; 2026 and 2027 the rate is 55%; and 2028 the enhanced CCA rate is nil. 7 See generally, Tenneco Canada Inc. v The Queen, 91 D.T.C. 5207 (F.C.A.) and more recently, Canada v. ...

Position: Reduced accommodation charges- no, XXXXXXXXXX Payments- yes, PUA payments – yes. ...

The second amount (in clause (i)(B) of the description of Variable B) is determined by the formula C – D, where C is the executive remuneration of the eligible entity, or of the public parent corporation that controls the eligible entity, if any, for the 2021 calendar year (prorated based upon the number of days of the eligible entity’s, or the public parent corporation’s, fiscal periods in the calendar year, if those fiscal periods are not the calendar year), and D is the executive remuneration of the eligible entity, or of the public parent corporation that controls the eligible entity, if any, for the 2019 calendar year (prorated based upon the number of days of the eligible entity’s, or the public parent corporation’s, fiscal periods in the calendar year, if those fiscal periods are not the calendar year). ...

The university issued a Form TL11A, Tuition and Enrollment Certificate – University Outside Canada (Form TL11A) and advised your son to use the letters of offer to report the scholarship and living allowance stipend amounts on his Canadian income tax and benefit return (Canadian Return). ...

It cannot exceed the amount determined by the formula A – B where: A is the income that the second CCPC has for its taxation year from the first CCPC referred to in paragraph 125(3.2)(a), and B is the portion of the amount described in A that is deductible by the first CCPC in respect of the amount of income of the first CCPC referred to in clauses 125(1)(a)(i)(A) or (B) for the year. ...