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Disclaiming beneficiary will not be considered to have received any proceeds of disposition for purposes of section 106 & 107; disclaimed interest will be considered to have been received "as a consequence of death for the purpose of 248(8); donation will qualify under 118.1; GAAR is not applicable. ... X was filed at the XXXXXXXXXX Tax Services Office under his Social Insurance Number XXXXXXXXXX; (b) " Estate Trustees" of the Estate of Mr. ...

Le paragraphe 81(4) de la Loi de l'impôt sur le revenu (la "Loi") prévoit une exemption d'un maximum de 1 000 $ dans le calcul du revenu d'un particulier. ... À cette fin, le législateur a prévu une exemption au paragraphe 81(4) de la Loi pour ne pas imposer (jusqu'à un maximum de 1 000 $) les volontaires qui reçoivent un dédommagement de leur employeur pour des dépenses personnelles engagées dans le cadre de leurs fonctions à titre de volontaire. ...

XXXXXXXXXX owns a XXXXXXXXXX % interest in XXXXXXXXXX. 3. The XXXXXXXXXX is owned and operated by XXXXXXXXXX under a joint venture agreement. 4. ... XXXXXXXXXX * XXXXXXXXXX XXXXXXXXXX 7. XXXXXXXXXX The cost of these houses to the employees is about $XXXXXXXXXX. ...

As of XXXXXXXXXX it had $XXXXXXXXXX of undeducted SR & ED expenditures and $XXXXXXXXXX of ITC to carry forward. ... Once ACO has used all of its ITC and SR & ED or at the time that revenue is generated from the new products resulting from the research, ACO will redeem its preferred shares and BCO will repay its loan to ACO. ...

Where a change of units does not result in a disposition, a T5008 Information Return is not required. 3) See 1) & 2) above XXXXXXXXXX 2000-004005 G. ... Document # 9905003(E) referenced in your letter of August 8 is a severed version of an advance income tax ruling to a specific mutual fund trust dealing with this issue. ...

XXXXXXXXXX 2000-004673 Danielle Bouffard À l'attention de XXXXXXXXXX Le 30 novembre 2000 Mesdames, Messieurs, Objet: Supplément de revenu garanti / Allocation au conjoint Lettre d'opinion 5-983124 du 5 juillet 1999 La présente est pour vous aviser que nous avons réexaminé le traitement fiscal du supplément de revenu garanti et de l'allocation au conjoint qui vous avait été décrit dans la lettre susmentionnée en titre. À moins d'indication contraire, tous les renvois législatifs ci-après sont des renvois aux dispositions de la Loi de l'impôt sur le revenu (" la Loi"). ...

ACo has approximately $XXXXXXXXXX of non-capital losses, $XXXXXXXXXX of unclaimed Scientific Research and Experimental Development (“SR & ED”) expenditures and $XXXXXXXXXX of unutilized Investment Tax Credit (“ITC”). ... Purpose of the Proposed Transactions Although both ACo and BCo are profitable, the purpose of the proposed transactions is to reduce taxes payable on a consolidated basis through the utilization of losses, the deduction of unclaimed SR & ED expenditures and the utilization of ITC’s that are available to ACo over a shorter period of time than would otherwise be achieved by virtue of the interest income. ...

These expenses are estimated to be as follows: Artists' Fees $ XXXXXXXXXX Artists' Marketing Fees XXXXXXXXXX Production costs XXXXXXXXXX Administrative, Marketing and Promotion XXXXXXXXXX Total expenses $ XXXXXXXXXX 11. ... The cash distributions to the Partners will be made on the following basis: a) For fiscal periods ending before XXXXXXXXXX % thereof to the General Partner and XXXXXXXXXX% thereof to the limited partners allocated equally among them on a unit pro rata basis. b) Thereafter, available cash will be distributed as XXXXXXXXXX% thereof to the General Partner and XXXXXXXXXX% thereof to the limited partners allocated equally among them on a unit pro rata basis. 19. ...

XXXXXXXXXX 2014-056322 XXXXXXXXXX, 2015 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX Further to your request for an amendment to our Advance Income Tax Ruling dated XXXXXXXXXX 2014, our file number 2014-0539791R3 (the "Ruling"), issued to the above named taxpayer, the Ruling is amended by: (1) Adding the following paragraph in the Definition section of the Ruling after paragraph (h): "(h.1) "Hedge Fund" means XXXXXXXXXX, a fund resident in XXXXXXXXXX;". (2) Amending the definition of "Non-Resident Holders" in paragraph (l) by replacing the words "and certain of its subsidiaries" with the words ", certain subsidiaries of the Bank, and the Hedge Fund;". (3) Amending the definition of "Settlement Agreement" in paragraph (t) by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (4) Amending paragraph 11 by replacing the words "the Non-Resident Noteholders" with the words "the Bank and certain of its subsidiaries". (5) Amending paragraph 15 by: (a) Replacing the words "The Non-Resident Noteholders" in the second sentence with the words "The Bank and certain of its subsidiaries"; (b) Adding the sentence "The Hedge Fund held XXXXXXXXXX% of the Notes outstanding. ...

XXXXXXXXXX 2004-010939 XXXXXXXXXX, 2005 Dear Sir: Re: Supplemental Advance Income Tax Ruling Request XXXXXXXXXX (the "Taxpayers") Further to your letter of XXXXXXXXXX, the following amendments are made to advance income tax ruling 2004-006027 that was issued to the Taxpayers on XXXXXXXXXX, 2004 (the "Ruling"): (a) paragraph 1(v) of the DEFINITIONS is deleted; (b) the references to "GCO", "XXXXXXXXXX Class G Preference" shares and "XXXXXXXXXX Class H Preference" shares in paragraph 4 are deleted; (c) the reference to "XXXXXXXXXX Class C Preference" shares in paragraph 4 of the Ruling is deleted and replaced with a reference to "XXXXXXXXXX Class E Preference" shares; (d) paragraph 5 is deleted; (e) paragraph 6 of the Ruling is deleted and replaced with " XCO is the sole shareholder of a number of subsidiary companies (the "Subsidiaries"), the shares of which are held by XCO as capital property for the purposes of the Act (the "Subsidiary Shares"); (f) the reference to "GCO," in paragraph 14 is deleted; (g) paragraph 48 is deleted; and (h) paragraph 1(d) of the COMMENTS is deleted and replaced with "any tax consequences relating to the facts and the proposed transactions described herein other than those described in the rulings given above". ...