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Seidel, CMA Technical Applications & (613) 957-2058 Valuations Division Attention: Bob Seney 2003-000063 Capital Cost Allowance This is in reply to your January 28, 2003 memorandum concerning the proper tax treatment of development costs related to XXXXXXXXXX. ...

As we have stated in the past (see, for example, documents #XXXXXXXXXX and # 2000-0047365), an IBC incorporated in Barbados would be a resident of Barbados for purposes of the Barbados Convention but for Article XXX(3) of that Convention and therefore would satisfy the test in paragraph 5907(11.2)(c) of the ITR since such an IBC is liable to tax in Barbados on its worldwide income (albeit at lower rates). ...

" In addition to the above test, the expenses must meet the additional test imposed by the preamble to subsection 20(1) of the Act which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto... ...

" In addition to the above test, the expenses must meet the additional test imposed by the preamble to subsection 20(1) of the Act which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto... ...

It is also to be noted that in cases involving theatrical shows where performances were given in different places, both the U.S. and New Zealand, which Tax Conventions use the same concepts of "permanent establishment" and "fixed base" as that found in the Convention, denied that a permanent establishment existed (see technical interpretation # E 2000-0036167). ...

., 3 & 6. See comments under Position. 4. Because of the 60-month exemption, the trust has no change in residence at the time that the contributor becomes resident in Canada; however the trust does become resident in Canada on January 1 of the year in which the conditions in 94(1)(a) and (b) are met such that a deemed disposition under 128.1(1) occurs before the trust becomes resident in Canada. 5. ...

"concept of source of production in resource allowance provisions is broader than in legislation where "development" must be distinguished from "production" April 13, 2000 Calgary Tax Services Office Resource Industries Section Denise Dalphy Attention: Bharat Patel (613) 957-9231 Oil & Gas Specialist 991848 1999-001191 Costs of Tangible Capital Property This is in reply to you facsimile transmission of July 7, 1999 concerning submissions dated June 2 and 18, 1999 that you received from XXXXXXXXXX. ...

No Reasons: Please refer to the analysis in the document March 22, 2001 INTERNATIONAL TAX DIRECTORATE HEADQUARTERS Transfer Pricing & Alison Campbell Competent Authority Attention: Tam Nguyen 2000-004916 XXXXXXXXXX Canadian Investment Fund- Unregistered Reinsurance Reserve XXXXXXXXXX Taxation Years (Your File XXXXXXXXXX) This is in reply to your memorandum of September 25, 2000, regarding the XXXXXXXXXX and its Canadian branch, hereinafter referred to as USCo and the Branch, respectively. ...

In the present case, the phrase "dependent … on …sales of goods" could thus, as argued by counsel for the respondent, include payments which are dependent on the sales of goods by third parties, like the sales by the manufacturers to Hasbro. ...