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Technical Interpretation - External

15 April 2009 External T.I. 2007-0262141E5 - Art XXIX A (2)(e)(i), LOB 5th Proto to Can US Tax

Yours truly, Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External

29 July 2009 External T.I. 2009-0312891E5 - Payments to Parent for Attendant Care

Justice Tardif J. stated at paragraph 28 that: "... the appellant was not an employee, since she was completely independent in the way she did her work, worked in her own environment with her own tools and was not in any way part of a third party's business. ...
Technical Interpretation - External

25 February 2010 External T.I. 2008-0302321E5 - Article XXI(2) Canada-Israel Treaty

For Director International & Trusts Division Income Tax Rulings Directorate Legislative and Regulatory Affairs Branch ENDNOTES 1 It is our understanding that an individual will be considered an Israeli resident if the individual's center of life is in Israel. ...
Technical Interpretation - External

9 December 2008 External T.I. 2008-0268281E5 - Bonds sold on secondary market

For Director International & Trusts Division Income Tax Rulings Directorate ENDNOTES 1 Subsection 214(7.1) will apply if the obligation was transferred from a person resident in Canada to a non-resident person, and back again. ...
Technical Interpretation - External

22 December 2008 External T.I. 2008-0302421E5 - 88(1)(d) Bump Negative ACB of Partnership Interest

. $500,000- (275,000) = $775,000]. In other words, it is your interpretation that the "negative ACB" of the partnership interest would increase the available "bump" room. ...
Technical Interpretation - External

15 January 2009 External T.I. 2008-0301331E5 - Solar Water heater

Depends on facts-- but generally yes Reasons: 2. as long as all the requirements are met & taxpayer claims CCA on cost net of grant per 13(7.1) XXXXXXXXXX 2008-030133 Lena Holloway January 15, 2009 Dear XXXXXXXXXX: This is in response to your electronic mail of November 21, 2008, wherein you requested our comments in respect of class 43.2 of Schedule II of the Income Tax Regulations (the "Regulations"). ...
Technical Interpretation - External

20 January 2009 External T.I. 2008-0284681E5 - Specified Investment Business

Yours truly, Sandy Parnanzone for Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External

27 January 2009 External T.I. 2008-0296431E5 - Remote Work Locations

If the employee only incurred $100 in actual transportation costs but received a $540 allowance (i.e. 20 days * $27 per day) it could be argued that the amount paid by the Employer is in excess of a reasonable amount. ...
Technical Interpretation - External

30 January 2009 External T.I. 2008-0299791E5 - Clergy Residence Deduction

In your submission you have indicated that the Reverend will be applying his experience as a pastor to nurture and grow a congregation which you refer as "XXXXXXXXXX ". ...
Technical Interpretation - External

26 March 2007 External T.I. 2006-0216421E5 - Transfer of Life Interest - Farm Property

Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

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