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22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(1) 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. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...

15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits Also released under document number 2003-00268270. ... January 15, 2004 ASSESSMENT & COLLECTIONS BRANCH HEADQUARTERS Individual Returns & Payment Processing Income Tax Rulings Directorate Directorate S. ...

7 August 1990 Income Tax Severed Letter- Cape Breton Investment Tax Credit Program — date of acquisition of property — foreign exchange rate Unedited CRA Tags none Subject: Cape Breton Investment Tax Credit (CBITC) Program_ Date of Acquisition of Property-Foreign Exchange Rate This is in reply to your Memorandum dated March 13, 1990 whereby you requested our opinion concerning the determination of the date of acquisition of certain equipment and the treatment of variations in exchange rates in respect of part of the purchase price paid before the date of acquisitions of the equipment. ... As stated in paragraph 6 of IT-50R: “... property can pass and acquisition take place only if the asset is in existence and, even then, only if it is a `specific asset', i.e. one that is capable of being identified as the object of the contract.” ...

6 August 1980 Income Tax Severed Letter RRRR15- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

6 August 1980 Income Tax Severed Letter RRRR16- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

18 June 2015 STEP Roundtable Q. 15, 2015-0572151C6- 2015 STEP – Q15- Tax Audit & Net Worth Statements CRA Tags 241 231.1(1) Principal Issues: Can CRA comment on auditors requesting personal financial information and/or furnishing statements of net worth of the shareholders of Canadian corporations? ... STEP CRA Roundtable – June 18 2015 Question 15. Tax Audit and Net Worth Statements Can CRA comment on the following: a) It has come to our attention that CRA is increasingly requesting personal financial information of the shareholders of Canadian corporations which are selected for audit. ...

15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Unedited CRA Tags 85; 261 Principal Issues: Whether the CRA can confirm in which currency amounts reported in form T2057 should be denominated in circumstances where section 85 applies in respect of a property transferred by a transferor that has a tax reporting currency different from that of the transferee. ... The first scenario of example 3 in paragraph 1.69 of the Folio S5-F4-C1 – Income Tax Reporting Currency (Feb. 27, 2019) provides an example of a situation where subsection 261(18) of the Act might be applicable. ...

7 January 1992 Income Tax Severed Letter 9134185- Maintenance payments — adult child — third parties Unedited CRA Tags 60(b), 60(c), 60.1(c), 60.1(1) 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. ... Subject: MAINTENANCE PAYMENTS ADULT CHILD THIRD PARTIES Section(s): 60(b), 60(c), 60.1(c), 60.1(1)] January 7, 1992 Appeals Branch Business and General Appeals & Referrals Division Division K. ...

15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés " Unedited CRA Tags 12(1)c) Principales Questions: Demande de précision concernant la position administrative de l'Agence du revenu du Canada énoncée dans les Nouvelles techniques no 30 où cette dernière utilise l'expression " intérêts explicitement identifiés ". ...

21 April 1997 External T.I. 9707215 F- % coproduction differe % cout production Unedited CRA Tags 125.4 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. ... Principales Questions: 125.4- % coproduction differe % participation depense Position Adoptée: De façon générale, le CI pour une société admissible correspond à 25% de sa "dépense de main-d'oeuvre admissible". ...