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May 19, 2009 Calgary TSO- Audit Division Income Tax Rulings Directorate 220- 4 Ave SE, Rm 130 Financial Sector & Exempt Entities Harry Hays Building Division Calgary, Alberta Robert Demeter, CGA T2G 0L1 (613) 952-1505 Attention: Tom Olsen 2009-031331 XXXXXXXXXX Part I.3 Implications, Central Banking Arrangement This is in response to your request for interpretation initiated on March 10, 2009. ...

" Although the Act does not specify what is meant by "meeting clients", the Oxford Canadian dictionary defines "meeting" as "an assembly of people and defines "meet" as: " a. encounter (a person or persons) by accident or design; come face to face with, b. ...

" [Emphasis added]. In my opinion, s. 12(1) operates so as to expand s. 9(1)'s ambit of inclusion. ...

Although the Act does not specify what is meant by "meeting clients", the Oxford Canadian dictionary defines "meeting" as "an assembly of people and defines "meet" as: " a. encounter (a person or persons) by accident or design; come face to face with, b. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Section 808(2) of the Regulations defines a corporation's "qualified investment in property in Canada at the end of the year" to include: (g) an amount equal to the aggregate of the cost amount to the corporation at the end of the year of each debt (...) owing to it (i) in respect of any transaction by virtue of which an amount has been included in computing its income for the year or from a previous year from a business carried on in Canada; or (i) an amount equal to the allowable liquid assets of the corporation at the end of the year. ...

Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Ce jugement indique que les deux enfants seront principalement sous la garde de la mère et que le père devra verser une pension alimentaire de XXXXXXXXXX $/mois/enfant, soit une somme de XXXXXXXXXX $ annuellement pour les deux enfants. ...

Robin Maley for Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ENDNOTES 1 This theme is reiterated in paragraph 2 of IT-128R ["...In this connection it is important to note that in computing the income of a partnership, subsection 96(1) and Regulations 1102(1a) require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"], and paragraph 15 of IT-285R2 ["It should be noted that, in calculating the income of a partnership, subsection 96(1) of the Act and subsection 1102(1a) of the Regulations require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"]. ...

Tax Services Office Position It is your position that the CRA interpretation outlined in paragraph 87 of IT-151R5 and confirmed in our technical interpretation # 2003-0047991I7 is correct. ...