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Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

John Oulton Section Chief Business, Property & Employment Section III Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch?? ...

The Queen, 74 DTC 1029. […] [28] The respondent's concern is unnecessary. ...

Section 60 states: “There may be deducted in computing a taxpayer’s income for a taxation year such of the following amounts as are applicable […] Canada Recovery Benefit Repayment (v.2) any benefit repayment payable by the taxpayer under section 8 of the Canada Recovery Benefits Act on or before the taxpayer’s balance-due day for the taxation year, to the extent that the amount was not deductible in computing the taxpayer’s income for any preceding taxation year;…” Therefore, a deduction for a CRB repayment may be claimed by a taxpayer if all of the following conditions are met: 1. ...

Notwithstanding any provision of this Convention: … (b) benefits under the social security legislation in a Contracting State paid in a calendar year to an individual who is a resident of the other Contracting State shall be taxable only in the State in which they arise and according to the laws of that State but the tax so charged shall not exceed the amount that the recipient would otherwise be required to pay in that year if the recipient were a resident of that first-mentioned State…” The Protocol of Understanding (“Protocol”) to the Treaty contains additional provisions, including paragraph (j) which states, in part, the following: “(j) For the purposes of subparagraph (b) of paragraph 3 of Article 18, the term “social security” means: (a) in the case of Canada, any pension or benefit paid under the Old Age Security Act of Canada” While both CPP and OAS payments may generally be considered to be social security benefits, only the OAS payments are considered to be social security benefits under the Treaty in accordance with paragraph (j) of the Protocol. ...

July 4, 2003 International Tax Directorate Resource Industries Section Policies & Publications Unit A.A. ... In our view, this latter point highlights the difference between the "dependent on the use of or production from property" test contained in paragraph 12(1)(g) of the Act (which the Courts have traditionally interpreted as a "continuous / on-going" basis test consistent with the predecessor to that paragraph which expressly provided for the "continuous" nature of this test), and the test contained in paragraph 212(1)(e) of the Act. The latter test only requires that "the consideration is...dependent on, or computed by reference to, the amount of timber cut or taken", disregarding whether the timber is cut or taken on a "one-time" basis or "continuous / on-going" basis. ...

On XXXXXXXXXX, an inspector of XXXXXXXXXX Tax Administration issued an English translation of a Declaration of residence ("XXXXXXXXXX ", "Declaration") to the effect that the Entity is a resident of XXXXXXXXXX within the meaning of article XXXXXXXXXX of the Convention for avoidance of double taxation between XXXXXXXXXX and Canada. 10. ...

January 23, 2008 HELEN PRICE HEADQUARTERS Estates & Trusts Section Income Tax Rulings Directorate Montreal TSO James Atkinson CGA Montreal, QC (519) 457-4832 Ref: 2007-025801 Qualified Small Business Corporation Shares This is in response to your email dated October 31, 2007, requesting our views concerning whether the shares of a corporation (Aco) meet the definition of "qualified small business corporation share" (QSBCS) in subsection 110.6(1) of the Income Tax Act (Act). ...

In this regard, form T2SCH 20, Part XIV – Additional Tax on Non- Resident Corporations is the schedule that computes the relevant amounts under subsection 219(1) of the Act. ...

Robin Maley Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...