Search - 江西农大 毛瑢

5 May 1995 External T.I. 9430895- CHILD CARE EXPENSE FOR UI RELATED BUSIN & EMPL INCOME Unedited CRA Tags 63(2) 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. ... Principal Issues: whether UI benefits received in conjuction with the self employment assistance program or the Unemployment Insurance Job Creation Program-section 25 qualify as earned income for purposes of the child care expense limitation Position TAKEN: no Reasons FOR POSITION TAKEN: the amounts received are benefits under the UI Act & are not in connection with the cost of a course or program designed to facilite re-entry into the labour force Youth Programs and Services Human Resources and Development Canada 4th Floor, Place du Portage, Phase IV 140 Promenade du Portage A. ...

29 June 1995 External T.I. 9505455- FLEX PLANS & CONVERSION OF SALARY TO CREDITS Unedited CRA Tags 5 56(2) 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. ... Principal Issues: 1. conversion of salary & other taxable amounts to flex credits 2. cash out of credits to a health spending account Position TAKEN: 1. taxable at the time of conversion under 56(2) and 5(1) 2. cash out provision disqualifies a health spending account as a phsp Reasons FOR POSITION TAKEN: 1. ...

17 July 1995 External T.I. 9500075- VACATION BUYING & SELLING IN A FLEX PLAN Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: whether a flexible benefit plan which permits the purchase of vacation will be considered a salary deferral arrangement Position TAKEN: question of fact Reasons FOR POSITION TAKEN: if a plan permits the carryforward of purchased vacation, such a plan could be a SDA depending on whether the potential tax deferral associated with such a carryforward can be considered one of the main purposes of the arrangement & thus we will not rule or offer an opinion. ...

14 September 1995 External T.I. 9515775- FAMILY MORTGAGE PLAN ARRANGEMENT- 56(2) & 56(4) Unedited CRA Tags 56(2) 56(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. ... Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

22 November 1995 External T.I. 9518245- SCC EGAN & EFFECT ON SAME SEX PARTNERS HEALTH PLAN Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: details on how to segregate one plan so that the part that qualifies as phsp will not be considered an ebp & whether SCC decision in Egan v the Queen will impact on our position Position: separate plans require no cross-susidization-the SCC decision upholds the OAS extended def'n of spouse so there is no reason to believe that the ITA distinction would offend the Charter Reasons: see above A. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS Unedited CRA Tags 181(1) 181(3) 181.2(3) 181.2(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. ... Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch?? ...

24 April 2003 Internal T.I. 2002-0169537- SR & ED- ACQUIRING RIGHTS Also released under document number 2002-01695370. ... Canco 1 has represented that the Software was used as a tool to assist in the development of its technology / product, and that the Software could not directly achieve the goals initially set out and was rendered virtually useless. ...

3 January 2002 External T.I. 2001-0067955- Application of 75(2) & 107(4.1) to a trust Unedited CRA Tags 75(2) 107(4.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

22 January 2002 Internal T.I. 2001-0105567- FTC & SBD- PATRONAGE DIVIDEND Unedited CRA Tags 125(1) 135(7) 126(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 CCRA. ... Holloway Verification & Enforcement Division (613)- 957-2104 ATTENTION: Patricia Caron 2001-010556 Foreign Tax Credit and Small Business Deduction override This memorandum is in response to your faxed memorandum of October 12, 2001. ...

16 May 2002 External T.I. 2002-0135765- E-Commerce & Computer Software Unedited CRA Tags 212(1)(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Position Paper Internet Commerce, which evolved from 2 sources:- a 1998 CCRA Technical Advisory Group (TAG) on Interpretation & International Cooperation; and- The "Taxation Framework Conditions", agreed upon in Ottawa in 1998 by member countries of the OECD. 2. ...