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16 May 2002 External T.I. 2002-0135765- E-Commerce & Computer Software Unedited CRA Tags 212(1)(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Position Paper Internet Commerce, which evolved from 2 sources:- a 1998 CCRA Technical Advisory Group (TAG) on Interpretation & International Cooperation; and- The "Taxation Framework Conditions", agreed upon in Ottawa in 1998 by member countries of the OECD. 2. ...

22 October 2002 External T.I. 2002-0161565- DIRECTOR & OTHER FEES Unedited CRA Tags 6(1)(c) 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. ... Subsection 5(1) of the Act states that "... a taxpayer's income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by the taxpayer in the year". ...

24 January 2003 External T.I. 2002-0180955- Active Solar System & Cogeneration Equip. ... With regard to the heat distribution system and the cost of buildings and structures that support and house the micro-turbine units, the postamble of paragraph (a) of Class 43.1 describes property that cannot be included in the class under that paragraph, namely: ".... buildings or other structures, heat rejection equipment (such as condensers and cooling water systems), transmission equipment, distribution equipment, fuel storage facilities and fuel handling equipment," Since distribution equipment is specifically excluded, in our view, none of the components of the heat distribution system is eligible for inclusion in Class 43.1. ...

14 December 2000 External T.I. 2000-0044105- SHAREHOLDER LOANS & REPAYMENTS Unedited CRA Tags 15(2) 15(2.6) 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. ... Reasons: The exception will only apply if the loans and repayments are not part of " a series of loans or other transactions and repayments". ...

16 November 2020 External T.I. 2020-0864141E5- TI – Tax Treatment of Loan Forgiveness under CEBA Unedited CRA Tags 12(1)(x); 12(2.2); 80 * Principal Issues: What is the tax treatment of forgiveable portion of a loan granted under the CEBA program? ...

2 December 2020 External T.I. 2020-0869481E5- METC & Lump sums in lieu of coverage under a PHSP Unedited CRA Tags 6(3)(b); 118.2(3)(b) Principal Issues: Whether a lump sum amount received by a retiree in lieu of the continuation of medical and dental coverage under a PHSP will reduce amounts eligible for the medical expense tax credit. ... This provision applies for the purpose of subsection 118.2(1), that is, to medical expenses “that were paid by the individual […].” ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease CRA Tags 66(15) "Canadian resource property" 66.4 Principal Issues: How is an amount received for granting a lease of rights to explore for, drill for or extract petroleum, natural gas or other hydrocarbons reported for income tax purposes? ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

10 June 2015 External T.I. 2015-0580531E5- joint account & estate returns CRA Tags 104(13) 70(5) Principal Issues: TREATMENT OF PROPERTY HELD IN JOINT OWNERSHIP AT DEATH Position: LEGAL DETERMINATION REQUIRED Reasons: TAX TREATMENT DEPENDS ON LEGAL & BENEFICIAL OWNERSHIP OF THE PROPERTY. ...

19 September 1997 External T.I. 9722075- CHELATION THERAPY & PER KM RATE FOR MEDICAL TRAVEL Unedited CRA Tags 118.2(2)(h) 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: chelation therapy and the cost related to medical travel by automobile that is not supported by receipts Position: cost of prescription drugs & fees to physician for chelation therapy qualify as a medical expense. ...

26 May 1998 External T.I. 9805745- SALARY / BONUS- REASONABLENESS Unedited CRA Tags 67 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: Reasonableness of bonuses paid to shareholders / employees Position: As stated in question 42 of the 1981 Round Table (as clarified in Insights into the 1991 Revenue Canada Round Table Discussion), the Department will not challenge the reasonableness of salaries or bonuses paid to a principal shareholder who is active in the corporation’s business and the corporation has either established 1) a practice of distributing profits to such employee/shareholder in this manner, or 2) a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that in fact are attributable to special know-how or skills of the shareholder. ...