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Storry GAAR & Technical Support Section 957-3499 2000-005101 Strong Currency Loan Hedged by a Cross Currency Interest Rate Swap This is in reply to your memorandum of October 11, 2000, wherein you requested our views regarding payments made under a cross currency interest rate swap and whether such payments should be recharacterized as interest for purposes of Part XIII of the Income Tax Act (the "Act") when the desired currency was Canadian dollars and when the parties to the swaps and the underlying loans being hedged are all related. ...

July 13, 2001 Toronto Centre Tax Services Office HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

October 3, 2001 Headquarters Headquarters SR & ED Directorate Income Tax Rulings Directorate Attn: Kevin Gibson F. ...

A sold XXXXXXXXXX % of his Opco shares to his adult son ("S") and XXXXXXXXXX% of his Opco shares to his daughter-in-law ("D"). ...

The postamble of the definition states, in part, "... and, for the purposes of this definition,... ...

& Yukon Tax Services Cornelis Rystenbil, CGA Aboriginal Affairs Section (613) 941-6547 2002-012281 RRSP Over-Contributions This letter is in response to your e-mail of February 7, 2002 in which you ask our views on several issues as they relate to Registered Retirement Savings Plan (RRSP) over-contributions made by members of the XXXXXXXXXX First Nation. a) Our Comments For purposes of this memorandum, the expression "Indian" has the meaning assigned by subsection 2(1) of the Indian Act. ...

" À notre avis, dans la situation que vous nous présentez, une partie du fonds de terre doit être attribuable à la location d'une partie du bâtiment puisqu'il serait peu probable qu'aucune partie du fonds de terre ne sert à la partie louée du duplex. ...

If so, then the terms were such that there would be an excluded production, as explained in our prior responses on this file (files 2000-005368 & 2001-006946). ...

We would also note that subsections 220(6) & (7) of the Act recognize that in certain instances a FTC refund may be assigned to another party. ...

The corporate taxpayer's XXXXXXXXXX taxation year was assessed on XXXXXXXXXX with nil tax payable and an overpayment of tax of $XXXXXXXXXX and interest of $ XXXXXXXXXX. ...