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Robin Maley for Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ENDNOTES 1 This theme is reiterated in paragraph 2 of IT-128R ["...In this connection it is important to note that in computing the income of a partnership, subsection 96(1) and Regulations 1102(1a) require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"], and paragraph 15 of IT-285R2 ["It should be noted that, in calculating the income of a partnership, subsection 96(1) of the Act and subsection 1102(1a) of the Regulations require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"]. ...

Tax Services Office Position It is your position that the CRA interpretation outlined in paragraph 87 of IT-151R5 and confirmed in our technical interpretation # 2003-0047991I7 is correct. ...

Robin Maley for Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ENDNOTES 1 We note that clause 53(2)(c)(ii)(C) of the Act provides for a reduction in computing a partner's adjusted cost base of their Partnership interest at any particular point in time by an amount in respect of each fiscal period of the Partnership ending before that time, equal to that partner's share of the CEE, if any, incurred by the Partnership in the fiscal period. ...

Lorsque le propriétaire du condo est une personne non-résidente, XXXXXXXXXX effectue une retenue d'impôt de la Partie XIII à l'égard du montant effectivement versé au propriétaire, soit XXXXXXXXXX% ou XXXXXXXXXX % du revenu net de location. ...

Murphy Section Manager for Division Director International & Trusts Division Policy and Planning Branch Policy and Legislation Branch?? ...

Lee Workman Manager Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch Attachments ...

Position The Department of Finance has announced in its Press Release # 98-129 dated December 18, 1998 that amounts that are required to be included in an individual’s income under the I.R. ...

" In particular the provisions were set forth in the principle clauses as follows: "2.Notwithstanding the rate of interest in the said Mortgage provided, when there is no default under the said Mortgage, the interest payable and to be paid by the Mortgagor shall be, where mortgage payments are fully adjusted to fluctuations in the average commodity price or index, 6% per annum calculated half yearly, not in advance, or where mortgage payments are not so fully adjusted to such fluctuations,_ % per annum calculated half yearly, not in advance. 5. ...

Brooks Small & Medium Business 957-8953 erprises Division Attention: Luisa Guyan 963510 XXXXXXXXXX This is in reply to your request of October 18, 1996 in which you requested our views on the taxability of business income earned by XXXXXXXXXX (the "Taxpayer") from his consulting business. ...

Chouinard A/Section Chief Business, Property & Employment Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...