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Technical Interpretation - Internal

11 October 2000 Internal T.I. 2000-0044071I7 - Environmental Assessment Expenses

". In my view, this provision is to be interpreted as it would be understood in the mining industry, for which Parliament included Canadian exploration expense as defined in s/p (iii.1) as a benefit to attract investment in resource production. ...
Ruling

2005 Ruling 2004-0096311R3 - Deferred Share Units - Bonus Plan

If Annual Individual Goals and Annual Corporate Goals are only partially attained, the Participant may be entitled to receive a pro-rata portion of the Performance Vesting RSUs, the number of which will be determined at the discretion of the CEO or the Chair of the Board, as the case may be. e) No Participant shall be entitled to any benefit in respect of RSUs granted under the Plan to the extent that such RSUs have not vested in favour of the Participant. f) Subject to subparagraph 8(o) below, any RSUs applicable to a particular Grant to which a Participant does not become entitled under the Time Vesting Criteria, the Annual Corporate Goals or the Annual Individual Goals shall be forfeited immediately upon such determination. g) Upon the vesting of RSUs under the Plan, Pubco will determine the amount that is payable to a Participant based on the following formula: (Vested RSUs x Average Market Price on the Entitlement Date)- Tax Withholding = funds payable to the Participant h) The amount payable to the Participant (based upon the formula in subparagraph (g) above) will be paid to the Participant in cash. i) Pubco will pay amounts owing under the Plan to the Participant each year in which a Participant's RSUs vest. ...
Technical Interpretation - Internal

28 June 2013 Internal T.I. 2013-0474311I7 - Indian - employment income

Payroll Services Company, for and on behalf of Company One, shall charge back to Company One's customers the total cost of labour above + XXXXXXXXXX% premium for employee management, unless otherwise agreed to in writing. ...
Technical Interpretation - External

28 January 2014 External T.I. 2013-0506991E5 - Prescribed Security Interest

., at paragraph 17, summarized the findings of the Supreme Court in First Vancouver as follows: The collection of source deductions is at the heart of income tax collection; The tax debtor's bank is more familiar with the debtor's business and finances than the Minister; Source deductions have priority over other creditors with respect to the collection of unremitted taxes; The special priority granted to the deemed trust prevails over property given as security, regardless of whether the security interest arose before or after the deductions for income tax or employment insurance were made [.] ...
Ruling

2012 Ruling 2012-0466731R3 - Donation of flow-through shares

There will be two forms of subscription agreement – one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX, and one for residents of XXXXXXXXXX under which the Resource Company will incur exploration expenses in XXXXXXXXXX. ...
Ruling

2014 Ruling 2013-0510551R3 - Upstream Loans - Specified Debtor

Yours truly, XXXXXXXXXX Manager for Director International & Partnerships Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2013 Ruling 2012-0464841R3 - Distribution by a trust

Opco will reorganize its share capital and will file Articles of Amendment in order to: a) Delete the authorized but unissued non-voting preference shares in their entirety as well as all rights and restrictions attaching thereto; b) Create an unlimited number of Class A common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; c) Create an unlimited number of Class B common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; d) Create an unlimited number of Class D common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; e) Create an unlimited number of Class W common shares, voting (as to XXXXXXXXXX votes per share), carrying the right to dividends declarable at the discretion of the Board of Directors; f) Create XXXXXXXXXX Class A preferred shares which shall be non-voting, carrying annual dividends in the aggregate amount of $XXXXXXXXXX, redeemable and retractable as described in Article XXXXXXXXXX, respectively, of the Articles of Amendment (the "Redemption Amount – Class A"). ...
Ruling

2012 Ruling 2011-0426581R3 - Loss and XXXXXXXXXX tax consolidation

., document # XXXXXXXXXX) for this taxpayer except that the Proposed Transactions not only involve the utilization of Creditco's non-capital losses but also the XXXXXXXXXX tax credits of Creditco in respect of claims made in the XXXXXXXXXX to XXXXXXXXXX taxation years, and in the current and future taxation years. ...
Ruling

2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation

With the exception of XXXXXXXXXX support, the XXXXXXXXXX program functions separately from the remaining operations of the Charity, including with respect to matters involving XXXXXXXXXX – all of which are the responsibility of a committee of the XXXXXXXXXX, not the Charity's Board of Directors. 7. ...
Ruling

2014 Ruling 2013-0516071R3 - Reorganization

Unless otherwise stated, all statutory references herein are to the Act; "ACB" is the acronym for "adjusted cost base," which has the meaning assigned by section 54; "Amalco" has the meaning assigned in paragraph 26; "Amalco Preferred Shares" has the meaning assigned in paragraph 26; "Amalco Preferred Share Redemption Amount" has the meaning assigned in paragraph 26; "Amalco Redemption Note" has the meaning assigned in paragraph 28(c); "CRA" means Canada Revenue Agency; "dollars" or "$" means Canadian dollars; "EAI" is the acronym for "eligible alignment income" which has the meaning assigned in subsection 34.2(1); "Foreign Parent 1" means XXXXXXXXXX, a XXXXXXXXXX corporation; "Foreign Parent 2" means XXXXXXXXXX, a XXXXXXXXXX corporation; "GPco 1" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "GPco 2" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; "Lossco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Lossco Preferred Shares" has the meaning assigned in paragraph 21; "Lossco Preferred Share Redemption Amount" has the meaning assigned in paragraph 21(b); "LP1" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP1 Units" mean the limited partnership units of LP1; "LP2" means XXXXXXXXXX, a partnership governed by the XXXXXXXXXX; "LP2 Units" means the limited partnership units of LP2; "multi-tier alignment election" has the meaning assigned by subsection 249.1(9); "Newco" has the meaning assigned in paragraph 23; "Profitco" means XXXXXXXXXX, a corporation governed by the XXXXXXXXXX; "Profitco Preferred Shares" has the meaning assigned in paragraph 22; "Profitco Preferred Share Redemption Amount" has the meaning assigned in paragraph 22(b); "Profitco Redemption Note" has the meaning assigned in paragraph 28(d); "QTI" is the acronym for "qualifying transitional income," which has the meaning assigned in subsection 34.2(1); "Subco" means XXXXXXXXXX, an unlimited liability company governed by the XXXXXXXXXX; and "taxable Canadian corporation" has the meaning assigned in subsection 89(1). ...

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