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Technical Interpretation - Internal summary

25 September 2013 Internal T.I. 2013-0476311I7 F - 93(2), 93(2.01) - Share substituted -- summary under Subsection 93(2.01)

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...
Technical Interpretation - Internal summary

12 July 2007 Internal T.I. 2007-0240681I7 F - Indiens - Cotisations à un RPA -- summary under Paragraph 147.2(4)(a)

The Directorate stated: The fact that employment income from 1979 to 1981 was exempt is not in itself determinative of the taxpayer's entitlement to the paragraph 8(1)(m) deduction in 2006. Consequently the Contributions may be deducted in computing the taxpayer's taxable employment income in 2006 to the extent permitted by subsection 147.2(4). Where an expense relates to both on-reserve and off-reserve income the taxpayer must prorate the expense in question to determine the taxpayer's net employment income that is exempt …. ...

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