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11 January 1990 Ministerial Correspondence 59284 F- General Anti-avoidance Rule Unedited CRA Tags 110.6(1) qualified small business corporation share, 110.6(2.1), 248(1) small business corporation 19(1) File No. 5-9284   S. ...

1 September 1989 Ministerial Correspondence 74144 F- Deductibility of Allowable Business Investment Loss and Subsequent Carrying Charges Unedited CRA Tags 40(2)(g)(ii)   September 1, 1989 TORONTO DISTRICT OFFICE Small Business and Internal Audit General Division Chief Bill Guglich M. ...

Section 3 of Ontario Regulation 865/93 – Registration of the Ontario Medicine Act, 1991 sets out the standards and qualifications for a certificate of registration authorizing independent practice. ...

10 May 2012 Ministerial Correspondence 2012-0439001M4- Canada-Singapore Tax Treaty Unedited CRA Tags 2(1), 2(3), Article IV & XIV of the Can-Singapore tax treaty Principal Issues: Whether you will be subject to Canadian taxation under the Canada-Singapore tax treaty where you are working in Singapore for greater than 183 days in a calendar year. ...

. … [22] The appellant’s activity here has the necessary ingredients of commerciality to make it a business- the commitment of substantial capital, the organized and businesslike way in which records are kept and the devotion of enormous amounts of time by the appellant and his wife and, in earlier years at least, his sons as well as the intent to earn a profit. ...

Bonnie Ruttan-Morillo 905-721-5094 File # 2012-043344 or 2011-043096 ...

26 November 2009 Ministerial Correspondence 2009-0342521M4- HRTC- Eligibility of Private Care Homes Unedited CRA Tags Bill C51 (2009) / Draft section 118.04 of the ITA Principal Issues: Are owners of private care homes allowed to claim the HRTC? ...

Reasons: 1 & 2. Generally, the eligible expenditures include expenses for building materials, fixtures, equipment rentals, building plans and permits. ...

Yours sincerely, Denis Lefebvre Assistant Deputy Minister Policy and Legislation Branch Attachments Roxane Brazeau-LeBlond 957-2131 March 10, 1997 COMPARATIVE TABLE TAX CONSEQUENCES LAWYER APPOINTED TO THE BENCH ON APRIL 1, 1994, 1995 OR 1996 Assumptions: Lawyer is self-employed Financial year end: January 31 Professional income is $15,000 per month, $180,000 per year Salary as a judge: $10,000 per month, $120,000 per year Tax consequences A- Appointment on April 1, 1994 Taxation year 1994 1995 Salary (9 months- 12 months) $90,000 $120,000 Professional income 31-01-94: $180,000 Section 24.1 election $45,000 $135,000 Professional income 01-02 to 31-03-94: $30,000 Section 25 election- $30,000 Total income $135,000 $285,000 $420,000 B- Appointment on April 1, 1995 Taxation year 1995 1996 Salary (9 months- 12 months) $90,000 $120,000 Professional income 31-01-95: $180,000 Section 24.1 election $45,000 $135,000 Professional income 01-02 to 31-03-95: $30,000 Section 25 election $30,000- B- Appointment on April 1, 1995 (cont'd) Amount to be included 34.1 and 34.1(8)(a)-- Reserve- 34.2(4) 95% x $30,000 ($28,500)- Reserve to be included 34.2(5)- $28,500 Total income $136,500 $283,500 $420,000 C- Appointment on April 1, 1996 Taxation year 1995 1996 1997 Salary- $90,000 $120,000 Professional income 31-01 $180,000 $180,000- Amount to be included 34.1(1) 334/365 x $180,000 $164,712-- Amount to be deducted 34.1(3)- ($164,712)- Reserve- 34.2(4) 95% x $164,712 ($156,476)-- 85% x $164,712- ($140,005)- Reserve to be included 34.2(5)- $156,476 $140,005 Professional income 01-02 to 31-03-96- $30,000- Total income $151,759 $ $260,005 $411,764 ...

Yours sincerely, Bill McCloskey Assistant Commissioner Policy & Legislation Branch Mary Pat Baldwin 823-2631 2003-004356 November 25, 2003 ...