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Technical Interpretation - Internal

3 October 2000 Internal T.I. 2000-0030737 - Subpar 152(4)(b)(iii) and FAPI

A) Canco incorporates and capitalises a 100 % owned controlled foreign affiliate ("CFA") after 1995. ...
Technical Interpretation - Internal

27 October 2000 Internal T.I. 2000-0049497 - CUSTOMS OFFICE ON FORMER RESERVE LAND

Canada (Min. of Indian & Northern Affairs) confirmed that surrendered land is something different from a reserve and no longer forms part of a reserve. ...
Technical Interpretation - Internal

15 September 2000 Internal T.I. 2000-0008807 - STANDBY CHARGE-MULTIPLE PLACES OF BUSINESS

The word "regularly" means "... constantly... steadily... ...
Technical Interpretation - Internal

6 November 2000 Internal T.I. 2000-0036817 - RENOVATIONS-DWELLING

John Oulton Manager Business, Property & Employment Section III Business and Publications Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...
Technical Interpretation - Internal

15 November 2000 Internal T.I. 2000-0041917 - CHILD SUPPORT ORDER

Paragraph 2 of the variation order changes the amount of child support to "... ...
Technical Interpretation - Internal

1 December 2000 Internal T.I. 2000-0051587 - SOCIAL ASSISTANCE PAYMENTS

Principal Issues: What is the tax implication of payments to a corporation from the BC Ministry for Children & Families for the care of two mentally challenged individuals who reside in the home of the corporation's shareholder? ...
Technical Interpretation - Internal

9 January 2001 Internal T.I. 2000-0061537 - Retiring allowance paid to non-resident

January 9, 2001 Calgary Tax Services Office HEADQUARTERS Small & Medium Business Audit Karen Power, CA (613) 957-8953 Attention: Bob Gray 2000-006153 Taxation of a Retiring Allowance and Application of Section 80.4 to a Non-Resident We are replying to your letter of December 13, 2000, in which you requested our opinion on whether the payment of a retiring allowance to a non-resident of Canada would be subject to Part I tax. ...
Technical Interpretation - Internal

23 January 2001 Internal T.I. 2000-0062487 - CORP. NOT LICENSED TO SELL MUTUAL FUNDS

January 23, 2001 XXXXXXXXXX Tax Services Office HEADQUARTERS Small & Medium Business Audit J. ...
Technical Interpretation - Internal

19 December 2000 Internal T.I. 2000-0053237 - LIQUIDATOR RETIRING ALLOWANCE

December 19, 2000 XXXXXXXXXX TAX SERVICES OFFICE HEADQUARTERS Verification & Enforcement Division M.P. ...
Technical Interpretation - Internal

1 December 2000 Internal T.I. 2000-0053687 - Film Tax Credits; Investor Rules

Position: yes Reasons: Disposition of beneficial interest in production December 1, 2000 SR & ED Directorate Partnerships Section Financial Legislation Application Section Denise Dalphy Mel Machado, Manager (613) 957-9231 Attention: Alain Marchand 2000-005368 Canadian Film or Video Production Tax Credit- "Investor Rules" This is in response to your memorandum dated October 30, 2000, wherein you have asked for our views on the income tax consequences of a contract ("Contract") dated XXXXXXXXXX between XXXXXXXXXX ("Producer"), and XXXXXXXXXX ("Distributor") as it relates to the film, XXXXXXXXXX (the "picture"). ...

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