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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. ...

You are a status Indian, registered # XXXXXXXXXX, who lives in XXXXXXXXXX. ...

Applying this view to your questions, and assuming the requirements of subsection 110.6(15) are met, a) & b) When determining the QSBC status for the shares owned by Mr. ...

You indicate that you are a status Indian, registered # XXXXXXXXXX, who worked on reserve or Category 1 Lands for XXXXXXXXXX. ...

Because this "charging section" [subsection 220(2.1) of the Act] which permits the Minister to make such a waiver continues on to state that "... but the person shall provide the document or information at the Minister's request" [emphasis added], members of partnerships listed in paragraph 11 of IC 89-5R must file such a return if the Minister makes such a request. 2. ...

Diguer CGA Attention: XXXXXXXXXX August 9, 2000 Dear Sir: Re: Section 118.1 of the Income Tax Act (Canada) This is in reply to your letter dated May 29, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views on whether a charitable organization which has been named as the sole residual beneficiary of an estate of a deceased taxpayer (the "Estate") could be treated by the Estate as an income beneficiary in regards to periodic payments received by the Estate under a fixed term annuity. ...

Diguer CGA Attention: XXXXXXXXXX September 13, 2000 Dear Sir: Re: Repurchase of Debentures on the Open Market This is in reply to your facsimile dated July 11, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views on the tax consequences to a taxable Canadian corporation of a purchase, by it, of its debentures on the open market. ...

Prior to the introduction of subsections 220(6) and 220(7) of the Act, corporations would assign expected refunds of SR & ED investment tax credits or Film Tax Credits as security for bridge financing for their operations. ...

& 2. No, based on the facts as presented. Reasons: 1. Since the film is a treaty co-production, clause 1106(1)(a)(ii)(A) of the draft Regulations, at the definition of excluded production, does not apply to the film. 2. ...