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Technical Interpretation - Internal

19 October 2023 Internal T.I. 2020-0856851I7 - Ordinary Course of Business

More specifically, in technical interpretation 9203965 our Directorate stated: “... it is our view that where a corporation acquires shares of a wholly-owned subsidiary and the proceeds from the issue constitute permanent capital of the subsidiary such shares would not generally be considered to have been acquired in the ordinary course of the parent corporation's business…” In Canada v. ...
Technical Interpretation - Internal

1 May 2024 Internal T.I. 2024-1003041I7 - Ontario Made Manufacturing ITC ("OMMITC")

The condition set out in paragraph 3 of the eligible property definition is most relevant to this question: “‘eligible property’ means property that satisfies all of the following criteria: […] 3. ...
Technical Interpretation - Internal

20 March 2024 Internal T.I. 2023-0973071I7 - DeFi deposit and rewards

A barter transaction is effected when any two persons agree to a reciprocal exchange of goods or services and carry out that exchange usually without using money. […] 4. ...
Technical Interpretation - Internal

24 September 1999 Internal T.I. 9919789 - TAX CREDITS FOR U.S. STATE TAXES

., 0.5 x (average net income /0.095 + (0.75 x net worth))- $125,000). ...
Technical Interpretation - Internal

11 October 2000 Internal T.I. 2000-0044071I7 - Environmental Assessment Expenses

". In my view, this provision is to be interpreted as it would be understood in the mining industry, for which Parliament included Canadian exploration expense as defined in s/p (iii.1) as a benefit to attract investment in resource production. ...
Technical Interpretation - Internal

28 June 2013 Internal T.I. 2013-0474311I7 - Indian - employment income

Payroll Services Company, for and on behalf of Company One, shall charge back to Company One's customers the total cost of labour above + XXXXXXXXXX% premium for employee management, unless otherwise agreed to in writing. ...
Technical Interpretation - Internal

21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks

Frost and as evidenced by Standard & Poor's credit watch discussed above. ...
Technical Interpretation - Internal

11 March 1997 Internal T.I. 9701087 - INTEREST ON REASSESSED ADDITIONAL MINING TAXES

Cathie Figueira Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Ms. ...
Technical Interpretation - Internal

17 July 1997 Internal T.I. 9700547 - DEDUCTION OF TERMINAL LOSS FROM RESOURCE PROFITS

July 17, 1997 Calgary Tax Services Office Resource Industries Graham Hoard Section Acting Assistant Director Peter Lee Verification & Enforcement (613) 957-8977 Attention: Doug Reeh Large File Case Manager 7-970054 XXXXXXXXXX Terminal Loss and Resource Allowance This is in reply to your memorandum of January 2, 1997 wherein you requested our opinion on whether a terminal loss of $XXXXXXXXXX resulting from the disposition of its mining assets by the corporation formed in an amalgamation of XXXXXXXXXX, should be disallowed in computing the amalgamated corporation's income under the Income Tax Act (the "Act"). ...
Technical Interpretation - Internal

30 November 1997 Internal T.I. 980576B - RELATED GROUP LOSS UTILIZATION SCHEME

XXXXXXXXXX will realize a foreign exchange loss of approximately $XXXXXXXXXX on the assumption of Loan 1, as a result of the fluctuation in the exchange rate of US $ on the day of the assumption compared to the rate when the loan was made. 28. ...

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