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Chouinard A/Section Chief Business, Property & Employment Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Stalker Business Returns & Payments 957-2118 Processing Directorate 972121 Sections 110.5 and 161(7) of the Income Tax Act (Canada) (the "Act") We are writing in reply to your memorandum dated August 5, 1997 in respect of the application of section 161 of the Act where an amount is added back to taxable income pursuant to section 110.5 to utilize foreign tax credits carried back from a subsequent year. ...

Oulton Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch... ...

Obert A/Resource & Technical Officer 972673 Request for ruling- definition of "spouse" and "cohabiting spouse" This is in reply to Memorandum of October 3, 1997 in which you request clarification on the definition of "spouse" and "cohabiting spouse". ...

In those situations where XXXXXXXXXX does make advances to XXXXXXXXXX, the FTS Agreement provides that the advances shall be allocated as follows: “ XXXXXXXXXX XXXXXXXXXX,” Section 3 of the FTS Agreement provides that XXXXXXXXXX agrees to incur Canadian exploration expenses (“CEE”) and/or Canadian development expenses (“CDE”) “in an amount equal to or lower than the 1998 Advances” received from XXXXXXXXXX and that it will issue flow-through shares, at a price of $XXXXXXXXXX per share, in an amount equal to the amount of CEE/CDE actually incurred, ie. the amounts described in XXXXXXXXXX above. ...

Harding Appeals & Referrals Division (613) 957-8953 Loraine Tremblay Director Attention: Peter Bush 980886 XXXXXXXXXX Japanese Disability Pension Payments This is in reply to your memorandum of April 6,1998, in which you asked us if certain amounts received by the above-noted individual are taxable in Canada. ...

Moore Ministerial Correspondence Division 952-1506 Client Services Directorate Attention: Joao Melo 7-982151 XXXXXXXXXX In response to your request of August 18, 1998, we are providing you with the following insert to be included in reply to a query raised by the above-noted taxpayer regarding moving expenses: “ The Income Tax Act provides that certain moving expenses incurred by an individual are deductible when calculating income for the year. ...

LES FAITS Le XXXXXXXXXX, une société a déclaré, par voie d’une résolution de l’administrateur unique, un dividende en capital de XXXXXXXXXX $ payable le XXXXXXXXXX de la même année. ...

In our view, provided that all employees have access to the Municipalities facilities, the passes provided in situation 1 & 2 would not be considered taxable in the employee’s income. ...

The proposed legislation will apply to “... an amount paid or the value of assistance provided by any person in respect of, in the course of or because of, an individual’s office or employment...”. ...