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16 January 2008 External T.I. 2007-0260071E5- Instalment Interest & Penalties-Inter Vivos Trust Unedited CRA Tags 156 Principal Issues: Does the CRA assess instalment interest and penalties where an inter vivos trust does not make instalment payments? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc. Joffrine Mailhot, T1/T3 Returns Processing Section, Processing Division, Individual Returns & Payments Processing Directorate, Assessment and Benefit Services Branch ...

18 December 1990 External T.I. 9028685 F- Mortgage Investment Corporation Investments — Meaning of "Residential Property" Unedited CRA Tags 130.1(6)(f) 24(1) 5-902868   A. Seidel   (613) 957-8960 19(1) December 18, 1990 Dear Sirs: This is in reply to your letter dated August 21, 1990 with respect to paragraph 130.1(6)(f) of the Income Tax Act (the "Act"). ...

27 November 1990 External T.I. 901435 F- Canadian Manufacturing & Processing Profits Unedited CRA Tags 5202, 2900 24(1) 901435   J.D. Brooks   (613) 957-2097 19(1) November 27, 1990 Dear Sirs: Re:  Canadian Manufacturing and Processing Profits This is in reply to your letter of June 18, 1990 in which you requested our opinion regarding the definition of "scientific research" as referred to in the definition of "qualified activities" in section 5202 of the Income Tax Regulations. ...

23 January 2002 External T.I. 2001-0092005- TRUST & CAPITAL GAINS EXEMPTION Unedited CRA Tags 110.6(2) 104(21.2) 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. ... In particular see paragraphs 5-7, which state in part ¶ 5. A trust that has realized taxable capital gains in a particular taxation year may, within the limits of subsection 104(21), designate in its return of income for the year all or part of the amount of those gains as a taxable capital gain for the year of one or more beneficiaries. An amount designated to a beneficiary under subsection 104(21) must reasonably be considered to be part of the amount included in the beneficiary's income for that year under any of the provisions referred to in ¶ 1 above (see also ¶ 3 above)... ¶ 6. ...

22 October 1993 External T.I. 9317525- Frais de scolarité — Professionnels Unedited CRA Tags 8(1)(i)(i), 118.5   5-931752 XXXXXXXXXX Carole Chouinard   (613) 957-8953 A l'attention de XXXXXXXXXX Le 6 décembre 1993 Mesdames, Messieurs, Objet: Frais d'émission de permis de XXXXXXXXXX La présente est en réponse à votre lettre du 7 mai 1993 dans laquelle vous nous demandez notre opinion concernant l'admissibilité des frais d'émission de permis de l'organisme professionnel sus-mentionné à titre de frais de scolarité ou de cotisation professionnelle. ...

27 January 2001 External T.I. 9133106 F- SR&ED Accounting & Interest Expense Unedited CRA Tags 56(1)(u), 110(1)(d)(iii) January 27, 1992 Source Deductions Division Business and General A. ... Day   (613) 957-2136   913310 Subject: Respite Caregivers of the Province of Manitoba We are writing in reply to your memorandum of November 28, 1991, wherein you requested our comments regarding the income tax status of "Respite Caregivers" in the circumstances described in the referral from the Winnipeg District Office. 24(1) Respite care services may be provided, in the home of the recipient, in the home of the provider, at a camp or through a recreation/leisure program or such other location that is appropriate to the needs and wishes of the mentally handicapped persons. ...

17 September 1992 External T.I. 9209445 F- Deductibility of Insurance Premiums & IT-309R Unedited CRA Tags 20(1)(e)(ii)   920944 24(1) B.G. Dodd   (613) 957-3495 Attention:  19(1) September 17, 1992 Dear Sirs: Re:  Interpretation Bulletin IT-309R This is in reply to your letter dated March 19, 1992 requesting clarification of the Department's view's on the deductibility of insurance premiums as set out in IT-309R prior to the enactment of paragraph 20(1)(e.2) of the Income Tax Act (the "Act").  ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Is the income earned by a farmer for the rental of farmland to a third party who enters into FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ...

1 November 1991 External T.I. 91M11285 F- "Flow Through" of Deductions for Expenditures on SR & ED to Limited Partners Unedited CRA Tags 37 NOVEMBER 1991 QUESTION 16B Does section 37 permit the "flow through" of deductions for  expenditures on scientific research and experimental development to limited partners in a partnership which carries on a research business? ... BowenSection 31CCM # 912594 ...

22 January 2013 External T.I. 2012-0445401E5- Eligible Dependent – Support by Court Order CRA Tags 118.5(b) Principal Issues: Does a father who is required to pay child support able to claim the eligible dependent, even when the court order so indicates? Position: No Reasons: Legislation & Court positions XXXXXXXXXX 2012-044540 George A. ... Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...