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Reasons: Jurisprudence and previous interpretations November 29, 2012 Excise GST/HST Rulings HEADQUARTERS General Operations & Border Issues Income Tax Rulings Directorate Attention: Angela Stachowski L. ...

Further information on withholding obligations under these provisions is available in our Information Circular IC 75-6R2 — Required Withholding From Amounts Paid to Non-Resident Persons Performing Services in Canada. ...

December 23, 2013 Policy & Legislative Research Section HEADQUARTERS Trust Accounts Programs Division Income Tax Rulings Directorate Attention: May Ann McNulty Gillian Godson 2013-049881 Confidentiality and Non-resident Account Numbers We are writing in reply to your email of July 23, 2013, requesting our views on the application of section 241 of the Income Tax Act (the "Act") with respect to the confidentiality of Non-resident Account Numbers. ...

DATE May 9, 2013 TO Legislative Policy & Regulatory FROM Income Tax Rulings À Affairs Branch Directorate Legislative Policy Directorate DE P. ...

We also acknowledge our telephone conversations (Young / Carswell). We will not enumerate the specific facts as they are included in your draft memorandum, but we note that the taxpayer wishes to effectively deduct non-capital losses that expired in XXXXXXXXXX or earlier from income for its taxation year ending XXXXXXXXXX. ...

Interpretation Bulletin IT-273R2, "Government Assistance – General Comments" discusses the tax treatment of inducements and other forms of government assistance received by a taxpayer in the course of earning income from a business or property. ...

This letter is a follow-up to our previous letter dated April 22, 2014, in respect of File # 2014-052638. ...

In that case, the Minister did not accede to the taxpayer's request to substitute as Canadian exploration expenses the expenses that gave rise to non-capital losses for the 1980 – 1995 taxation years, and the Tax Court concurred. ...

March 11, 2014 T2 Strategy & Coordination Section HEADQUARTERS Assessment and Benefits Services Branch Income Tax Rulings Directorate Attention: Jeff Lewis Gillian Godson 2013-049942 Application of subsection 220(2.1) to subsection 129(1) We are writing in reply to your email of July 29, 2013, requesting our views on whether subsection 220(2.1) of the Income Tax Act (the "Act") provides the Minister with the discretion to waive the requirement in subsection 129(1) of the Act that a taxpayer file its return of income within three years of the end of the taxation year in order to allow the Minister to issue a dividend refund. ...

September 11, 2015 David Paradis HEADQUARTERS Senior Technical Specialist Income Tax Rulings Legislative Applications Section Directorate International & Large Business Directorate Lata Agarwal, CPA, Compliance Programs Branch CMA, MBA 2015-059916 Subject: Application of the thin capitalization rules to the non-resident corporations We are writing in response to your email of July 17, 2015, in which you requested our opinion on the application of the thin capitalization rules under subsection 18(4) (the “Rules”) of the Income Tax Act (the “Act”) to a non-resident corporation (the “Taxpayer”) who filed a return under section 216 of the Act for its 2013-2014 taxation year. ...