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Technical Interpretation - Internal

22 January 1999 Internal T.I. 9830327 - NORTHERN RESIDENTS DEDUCTION

Reasons: See File # 980159. “Travel expenses” includes air, train and bus fares, meals, hotel and motel accommodations, camping fees, incidentals such as taxis, road and ferry tolls, and automobile expenses directly related to the trip such as the cost of fuel, general maintenance (ex. oil, grease and servicing charges), repairs, licenses, and insurance as long as the costs are reasonable, are not on account of capital, and can reasonably be attributed to the trip. ...
Technical Interpretation - Internal

22 September 1994 Internal T.I. 9422817 F - PAIEMENTS INCITATIFS

Les intérêts sur l'emprunt déductibles totalisent XXXXXXXXXX $, soit la proportion des intérêts réclamés par le rapport entre la somme du capital versé des actions rachetées et des bénéfices non répartis et le montant payé pour le rachat des actions. 11. ...
Technical Interpretation - Internal

15 May 1996 Internal T.I. 9609447 - INDIAN EXEMPTION GUIDELINES AND "SITUS" OF THE CROWN

The Court did, however, also specify that "This does not necessarily mean that the physical location of the Crown is irrelevant to the purposes underlying the exemption from taxation provided by the Indian Act ". ...
Technical Interpretation - Internal

9 February 1995 Internal T.I. 9418527 - DAMAGES FOR EMPLOYMENT RELATED HUMAN RIGHT VIOLATION

Principal Issues:taxation of an out of court settlement pertaining to discrimination based on sex Position TAKEN:-settlement allocation unreasonable based on reported awards under the Ontario Human Rights Tribunals-amount for lost wages employment income-a reasonable amount for mental anguish & loss of dignity would be tax exempt-reimbursement of legal fees not taxable Reasons FOR POSITION TAKEN: the lost wages are not for loss of employment since she resigned voluntarily February 9, 1995 TORONTO CENTRE TAX SERVICES Rulings Directorate Source Deductions Division A. ...
Technical Interpretation - Internal

6 March 1995 Internal T.I. 9430707 - Money lending business

Bonner concluded that "... Mere repetition does not necessarily change the character of the activity...the level of activity shown in evidence is not indicative of the existence of a money lending business. ...
Technical Interpretation - Internal

4 May 1995 Internal T.I. 9509607 - PRINCIPAL RESIDENCE EXEMPTION AND CAPTIAL GAINS

M.N.R. (85 DTC 272) both contain comments regarding what "... can reasonably be regarded as contributing to the use and enjoyment of the housing unit as a principal residence... ...
Technical Interpretation - Internal

26 April 1995 Internal T.I. 9414306 F - FELLOWSHIP

The document is entitled " Statement on the Program of Visiting Fellowships in Canadian Government Laboratories" and provides a description of the Program of Visiting Fellowships, presumably for the benefit of applicants. ...
Technical Interpretation - Internal

14 November 1995 Internal T.I. 9524846 - consequential assessment

November 14, 1995 Appeals & Referrals Division HEADQUARTERS L. C. ...
Technical Interpretation - Internal

25 June 2003 Internal T.I. 2003-0021817 - DEDUCTIBILITY OF LUMP-SUM PAID IN YEAR

(our emphasis added) It is significant that the preamble to paragraph 20(1)(bb) refers to "... an amount other than a commission paid by the taxpayer in the year". ...
Technical Interpretation - Internal

8 August 2003 Internal T.I. 2003-0025837 - EXCHANGEABLE SHARES DEBT FORGIVENESS

" [emphasis added] Interpretation Bulletin IT-239R, Debtor's Gain on Settlement of Debt Paragraph 6 of IT-293R provides: " For a debt or obligation to be "settled or extinguished" all liability for payment must be terminated. ...

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