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15 June 2006 External T.I. 2006-0183921E5- Definition of Canada & Reg.105 Unedited CRA Tags 255 Reg.105 Principal Issues: (1) Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals... ... XXXXXXXXXX 2006-018392 June 15, 2006 Dear XXXXXXXXXX: Subject: Definition of "Canada" & Section 105 of the Income Tax Regulations This is in response to your request for our view on whether the extended definition of Canada in section 255 of the Income Tax Act (the "Act") applies in the circumstances set out below. ... Question 1 1-) Section 255 of the Act & Section 105 of the Regulations The term " Canada" is not defined in the Income Tax Act. ...

13 October 2004 Internal T.I. 2004-0060441I7- Hedging Gains / Losses of Partnership Unedited CRA Tags 20(1)(v.1) Reg 1206(3) Reg 1210(3) Principal Issues: Whether gains / losses realized by a partnership from a hedging activity may qualify for inclusion in the determination of the adjusted resource profits of a member of the partnership. Position: Yes, provided the hedging relates to qualifying production of the partnership such that the gains / losses would be included in the adjusted resource profits of the partnership but only the extent of the members share of such profits. ... Cameron Christine Savage (613) 347-1361 Co-ordinator, Resource Industries Attention: Zul Ladak 2004-006044 Hedging Gains / Losses of Partnership We are writing in response to your query regarding our memorandum dated December 9, 2003, wherein we provided comments in regard to certain Oil & Gas Audit Issue Sheets (our file 2003-00297). ...

18 June 2015 STEP Roundtable Q. 8, 2015-0581961C6- 2015 STEP – Q8- Foreign entity classification Principal Issues: Does CRA keep a list of foreign entities that it generally considers to be trusts. ... STEP CRA Roundtable – June 18, 2015 Question 8. Foreign Entity Classification The case of Sommerer highlighted the need for practitioners to carefully consider the issue of foreign entity classification when dealing with foreign legal entities / relationships. ...

26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6- AOA & Notional Expenses CRA Tags Treaties Article VII Principal Issues: Whether notional expenses determined under the AOA and attributable to a taxpayer’s permanent establishment in Canada can be deducted for Canadian tax purposes? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 2 – Authorized OECD Approach to Profit Attribution The possibility of deducting notional expenses in determining the profits attributable to a permanent establishment (“PE”) of a non-resident under Canada’s tax treaties was seemingly put to bed by the 1998 decision of the Federal Court of Appeal in Cudd Pressure (footnote 1). ... In respect of the Canada – United Kingdom Tax Convention, we would note that the new AOA-based Article 7 language was included in the convention by virtue of the protocol signed on July 21, 2014. ...

7 February 1994 External T.I. 9334745- Société en commandite — retraits de fonds Unedited CRA Tags 80, 53(2)(c)(v), 40(3) XXXXXXXXXX 5-933474 A l'attention de XXXXXXXXXX Le 7 février 1994 Mesdames, Messieurs, Objet: Société en commandite — Retraits de fonds La présente est en réponse à votre lettre du 11 novembre 1993 dans laquelle vous demandez notre opinion concernant l'acquisition, par deux individus, de la totalité des participations d'une société en commandite. ... Veuillez agréer, Mesdames, Messieurs, l'expression de nos salutations distinguées. pour le Directeur intérimaire Division des industries manufacturières,   des sociétés et des fiducies Direction des décisions Direction générale des affaires  législatives et intergouvernementales ...

HEALTH & SAFETY ACT) Unedited CRA Tags 18(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Is a fine imposed under the Occupational Health & Safety Act deductible in computing business or property income? ... Azzi December 19, 1995 Dear Sir: Re: Deductibility of Fines or Penalties This is in reply to your letter of October 10, 1995, wherein you request our views as to the deductibility of a fine imposed under the Occupational Health & Safety Act. ...

STEP CRA Roundtable – June 18, 2015 Question 14. Requirements for Question #6 on page 2 of the T3 Return Question 6 of the T3 return reads as follows: Did the trust borrow money, or incur a debt, in a non-arm's length transaction since June 18, 1971? ... The instructions for question 6 refer the reader to Interpretation Bulletin IT-406R2 – Tax Payable by an Inter Vivos Trust (the "IT"). ... Reference may be made to Folio S1-F5-C1 – Related persons and dealing at arm's length, for discussion as to the meaning of the term "at arm's length". ...

LLPs & LLLPs CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... Reasons: The provisions of the foreign legislation and the articles creating these entities support the general conclusion that these types of entities should generally be treated as corporations for the purposes of the Act. 2016 International Fiscal Association Conference CRA Roundtable Question 1 – Entity Classification: U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...

8 November 2022 Internal T.I. 2022-0942701I7- RCMP cadet training – service buyback Unedited CRA Tags 5, 6, 147.1(11), 8501(2), 8503(3)(a)(i) Principal Issues: In the circumstances, is the period of cadet training completed by an RCMP cadet eligible service for purposes of subparagraph 8503(3)(a)(i) of the Regulations? ... November 8, 2022 HEADQUARTERS HEADQUARTERS Registered Plans Directorate Income Tax Rulings Directorate Irina Schnitzer Attention: Jeff Boxer 2022-094270 Re: Royal Canadian Mounted Police (“RCMP”) Cadet Training – Eligible Service We are writing in response to your email dated July 5, 2022, wherein you requested our views on whether the period of cadet training completed by an RCMP cadet constitutes eligible service for purposes of subparagraph 8503(3)(a)(i) of the Income Tax Regulations (the “Regulations”). ... (footnote 1) In addition, in Dhillon v The Queen, 2002 DTC 2083 (“ Dhillon ”) the Tax Court of Canada concluded that in the circumstances presented at trial there was an employee/employer relationship between the RCMP cadet and the RCMP during the period of cadet training. ...

12 October 1993 External T.I. 9320490- Déductibilité des intérets — Interest Deductibility Unedited CRA Tags 20(1)(c) TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF — CONGRES 1993 Question 7 Dans le cadre du libre échange, Canco a incorporé une nouvelle filiale en propriété exclusive aux Etats-Unis("USCO") pour y étendre ses opérations. ...