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March 28, 2003 Summerside Tax Centre HEADQUARTERS E & A S.Parnanzone Mr. ...

The consulting income was received from a corporation XXXXXXXXXX % owned by the taxpayer's XXXXXXXXXX. ...

October 7, 2003 XXXXXXXXXX HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm XXXXXXXXXX Tax Services Office 613-957-8973 2003-003794 Deductibility of 20(1)(m) Reserve- Software Maintenance Plans We are writing in response to your memorandum of September 5, 2003, wherein you asked for our opinion on the deductibility of a reserve by XXXXXXXXXX (the "Taxpayer") under paragraph 20(1)(m) of the Income Tax Act (the "Act") in respect of a software maintenance plan. ...

November 20, 2003 XXXXXXXXXX HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

August 3, 2004 Charities Directorate Income Tax Rulings Policy & Communications Division Directorate Alison Campbell Attention: Jane Waterfall 957-3496 2004-008018 Donation of Private Corporation Shares to a Private Foundation We are writing in reply to your memorandum of June 3, 2004 requesting our views on several issues related to the donation of the shares of a private corporation to a private foundation by one of five directors of the foundation. ...

Yours truly, Eliza Erskine Acting Manager International Section I International Tax & Trusts Division Policy and Planning Branch ...

Our Comments In our letter of August 21, 1992, we stated that "... a share would be a "prescribed share" (as defined in section 6202.1 of the Regulations) and thereby not a flow-through share, if any of the conditions identified in paragraphs (a)- (f) of the Regulation are met. ...

May 10, 2001 Individual Returns & HEADQUARTERS Processing Directorate Denise Dalphy, LL.B. ...

XXXXXXXXXX states: "... if there were no agreement there would be no potential benefit and this issue would not arise. ...

The Agreement states that the payments of this income were to include "all entitlements you may have under Company policy, common law, as well as any statutory entitlements to notice pay, severance pay, and vacation pay you may have under the Employment Standard Act ". 4. ...