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Application Policy SR & ED 96-09 "Eligibility of Clinical Trials to Meet Regulatory Requirements"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work- Allowable SR&ED Expenditures".-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) PPT applied 1st like any other Treaty benefit limitation rule, any remaining benefit subject to GAAR scrutiny Question: How to the GAAR and PPT interact? ... S. 4.1 of the ITCIA provides that “notwithstanding the provisions of a Convention … the GAAR, applies to any benefit provided under the Convention.” ...

Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)".-- summary under Subsection 127(11.4) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(11.4) ...

Application Policy SR & ED 96-06 "Directly Undertaking, Supervising or Supporting v. 'Directly Engaged' SR & ED Salary and Wages".-- summary under Paragraph 37(8)(a) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(a) ...

Application Policy SR & ED 96-06 "Directly Undertaking, Supervising or Supporting v. 'Directly Engaged' SR & ED Salary and Wages".-- summary under Subsection 2900(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2900- Subsection 2900(2) ...

Application Policy SR & ED 96-04 "Payments to Third Parties for SR & ED".-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 majority of arbitration Articles provide for baseball-style arbitration Approximately 20 of Canada’s treaties will be updated to include arbitration. ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 4 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 4 post MLI, most of Canada’s treaties will have a residence tie-breaker rule When the Notice of Ways and Means motion for the implementation of MLI was tabled, Canada indicated that it would adopt additional provisions of the MLI including the tie-breaker rule for dual-resident entities. ...

3 November 1995 Interpretation 950229 – Sale of Rebuilt Cottage – ITCs on Costs Incurred for Rebuilding the Cottage-- summary under Section 192 Summary Under Tax Topics- Excise Tax Act- Section 192 rebuilding of fire-damaged cottage The subject cottage, that was rented out as a principal place of residence (ie., a residential complex) was subject to a fire in early 1995 that almost destroyed it. ...