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October 10, 2006 Jane Stalker HEADQUARTERS Coordinator, Natural Resources Income Tax Rulings Industry Specialist Services Directorate Technical Applications & Valuation Division Marc Edelson, LL.B. 112 Kent St., Room 1330 (613) 957-2123 Ottawa, Ontario K1A 0L5 2006-016905 Successor Pool Issues We are writing in reply to your memorandum of January 30, 2006, as subsequently amended on October 2, 2006, wherein you requested our views regarding various successor pool issues. ... More particularly, as an example subsection 66.7(5) reads: 66.7(5) "... where... a corporation (... ...

Monique Poirier International & Large Business Audit Section Montreal Tax Services Office 2008-028011 305 Rene-Levesque Boulevard West, 10th Floor S.E. ... For Director International & Trusts Division Income Tax Rulings Directorate ENDNOTES 1 Hope R. ...

In other words, the positions described in paragraphs 4 & 6 of IT-160R3 were intended to deal with friends and relatives. ... In this regard, you have stated "... the main activity of the heli-skiing is not for genuine business purposes, (i.e. personal) and although there may be some business purpose to the trip... ...

July 17, 2012 Policy & Legislative Research T. Posadovsky Trust Accounts Programs Division Taxpayer Services & Debt Management Branch 25 McArthur Road, Room 968 Place Vanier, Tower C Ottawa ON K1A 0L5 2011-042192 Attn: Joshua Drake Senior Programs Officer XXXXXXXXXX Special work site and remote work location We are writing in respect of the above-noted taxpayer (the “Employer”) and its advance income tax ruling request concerning the application of subsection 6(6) of the Income Tax Act (the “Act”). ...

May 2, 2013 Audit Division- Estates and Trusts Headquarters VITSO – 1415 Vancouver Street, Income Tax Rulings Victoria, BC V8V 3W4 Directorate V. ... " With respect to expenses incurred related to the disposition of a capital property, please refer to our comments in the recent CRA document – 2012-045790. ...

Upward adjustments made as per 247(2) essentially deem the sale price – an amount that was received or receivable – to be what it would have otherwise been had the parties been dealing at arm’s length. ...

MEMORANDUM NOTE DE SERVICE DATE March 19, 2012 TO Agnes Migneault FROM Senior Appeals Officer À Senior Appeals Officer DE Income Tax Rulings Directorate Tax and Charities Appeals Nancy Shea-Farrow Directorate 905-721-5099 Attention: Agnes Migneault + + FILE 2011-043079 DOSSIER SUBJECT: Education Tax Credit and Scholarship Exemption We are responding to your e-mail dated December 9, 2011 wherein you asked for our opinion on whether a teacher that is studying at a XXXXXXXXXX (the "Institution") in XXXXXXXXXX is entitled to the education tax credit (the 'Credit") and the scholarship exemption for the 2010 taxation year given recent amendments to the Income Tax Act (the "Act"). ...

In summary, the report concludes that "XXXXXXXXXX " and "XXXXXXXXXX " The facts indicate that there was an assemblage of properties yet the First Report does not consider this important fact. ...

Subsection 126(7) defines "business-income tax" as "the portion of any income or profits tax paid by the taxpayer for the year to the government of a country other than Canada that can reasonably be regarded as tax in respect of the income of the taxpayer from a business carried on by the taxpayer in the business country (...) ". The approach to determine whether a Canadian resident is carrying on business in another country for the purposes of the ITA can generally be summarized as follows: 1. ...

ACO reported the following income and expenses: XXXXXXXXXX XXXXXXXXXX Revenue $ $ Interest XXXXXXXXXX XXXXXXXXXX Dividends XXXXXXXXXX XXXXXXXXXX Foreign exchange gains(losses) XXXXXXXXXX Expense recoveries XXXXXXXXXX XXXXXXXXXX You have asked us several questions (some have been paraphrased and renumbered): 1. ...