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February 14, 2014 London TSO Income Tax Rulings Directorate Correspondence Unit Business & Employment Division 451 Talbot St. ...

XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

September 12, 2014 T2 Strategy & Coordination Section HEADQUARTERS Assessment and Benefits Services Branch Income Tax Rulings Directorate Attention: Jeff Lewis Gillian Godson 2014-051864 Adjustments to Corporate Minimum Tax in a statute-barred taxation year We are writing in reply to your email of January 15, 2014, requesting our views on whether subsection 152(4.3) of the Income Tax Act (the "Act") provides the Minister with the discretion to adjust the balances with respect to the Ontario Corporate Minimum Tax ("CMT") for a taxation year which is statute-barred, where the adjustments are a result of a reassessment of the previous tax year. ...

September 5, 2013 Paulette Salloum Bob Naufal T2 Strategy & Coordination Section IT Rulings Directorate Assessment and Benefit Services Branch 2013-048749 Credit Unions We are writing in response to your email dated May 1, 2013, wherein you asked whether a credit union that is a Canadian-controlled private corporation ("CCPC"), as defined in subsection 125(7) of the Income Tax Act (the "Act"), is required to file form T2SCH53, General Rate Income Pool (GRIP) Calculation or T2SCH54, Low Rate Income Pool (LRIP) Calculation with respect to eligible dividends paid in the year. ...

The Queen: It seems clear on reading the definition of farming in sec. 248(1) … that, since "farming" is defined as including the raising of poultry, together with other various agricultural activities, the enumeration of these matters is not intended to constitute an exhaustive definition and one must look to the common, ordinary and generally accepted meaning of the word as well as to the specific activities detailed in the statute. ...

Please refer to paragraph 7 of Interpretation Bulletin IT-433R, Farming or Fishing – Use of Cash Method. ...

November 8, 2012 Colette Fournier Income Tax Rulings Directorate Programs Officer Financial Industries Division Training & Content Support Section Nancy Shea-Farrow Taxpayer Services Directorate 905-721-5099 2012-044023 Subject: Common-law partners This is in response to your e-mail on March 15, 2012 asking what marital status should be indicated on an individual's income tax return (the "return") in the following situation. ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc XXXXXXXXXX, Income Tax Audit XXXXXXXXXX Tax Services Office ...

Canadian Pipelines & Petroleums Limited [1960] S.C.R. 126). Provided that the mining claims qualify as a "right to explore for minerals in a mineral resource in Canada", it is our view that the shares received by Mr. ...

The Canada Revenue Agency's Interpretation Bulletin IT-346R establishes an administrative position which allows a person who meets the definition of "speculator" at ¶ 6 of the Bulletin to elect to report the income resulting from such transactions, for income tax purposes, as being on account of capital instead of income. ...