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July 29, 2002 Marcel Querry International Section Policies & Publications- Unit II S. Leung Policy & Business Management Division 952-4666 International Tax Directorate 344, Slater Street, 6th Floor 2002-013740 Overseas Employment Tax Credit ("OETC") We are writing in response to your e-mail correspondence of April 29, 2002 in which you requested our comments on whether the employer in the situation outlined below would be considered to be carrying on business outside Canada for the purposes of subparagraph 122.3(1)(b)(i) of the Income Tax Act (the "Act"). ...

., 48 D.L.R. (3d) 613 at 616, Chief Justice Jackett stated that: '... as far as I know, under no system of law in Canada, does knowledge, skill or experience constitute "property" that can be the subject matter of a gift, grant or assignment... ... The provision therefore cannot apply.' To this, I would add that wages are not purchased but paid and that the result of such a proposition would affect all the departmental employees in a strange manner especially if one reads subsection 90(2) of the Indian Act, which states: 'Every transaction purporting to pass title to any property that is by this section deemed to be situated on a reserve, or any interest in such property, is void unless the transaction is entered into with the consent of the Minister or is entered into between members of a band or between the band and a member thereof.' " This case is not conclusive with respect to paragraph 90(1)(a) of the Indian Act and business income. ...

In paragraph 32.8, section F "Timing Mismatch" of the commentary on Article 23 B of the Model Tax Convention it is stated: […] Some States, however, do not follow the wording of Article 23 A or 23 B in their bilateral conventions and link the relief of double taxation that they give under tax conventions to what is provided under their domestic laws. ... In the case of Canada, such "other ways … to relieve the double taxation" include deductions allowed under subsections 20(11) and 20(12). ...

The relevant portion of the definition of “prescribed expenditure” reads as follows: “(b) an expenditure incurred by a taxpayer in respect of (i) …. ... Meaning of “Property” Subsection 248(1) of the Act defines “property” to mean: “... property of any kind whatever whether real or personal, immovable or movable, tangible or intangible, or corporeal or incorporeal and, without restricting the generality of the fore-going, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, (c) a timber resource property, (d) the work in progress of a business that is a profession, and (e) the goodwill of a business, as referred to in subsection 13(34);” The Law Dictionary Featuring Black’s Law Dictionary (2nd Ed) (footnote 5) defines “property” as the “ownership of a thing is the right of one or more persons to possess and use it to the exclusion of others...” ...

Le 15 juin 2000 Centre fiscal de Jonquière Administration centrale Service à la clientèle Patrick Massicotte (613) 957-9232 À l'attention de monsieur Robin Plourde Dossier # 2000-002442 Demande d'interprétation technique: paragraphe 56.1(4) de la Loi de l'impôt sur le revenu ("LIR" ou "la Loi") La présente est en réponse à votre demande du 5 mai 2000 pour laquelle vous désirez connaître notre opinion concernant le sujet susmentionné. ... En particulier, dans l'arrêt Pascoe (75 DTC 5427), la Cour d'appel fédérale a défini une "allocation" comme suit: "... ...

We could paraphrase Archambault J. at paragraph 101 reproduced above and cited with approval by the Federal Court of Appeal by saying that: The [...] benefit was conferred indirectly on [the taxpayer by Holdco], and that if [Holdco] had done it directly, the value of the benefit would have been included in [the taxpayer's] income, under subsection 15(1) of the Act. ...

Murphy Manager Trusts Section Resources, Partnerships & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

November 20, 2012 Small & Medium Enterprises Directorate HEADQUARTERS 112 Kent Street, 19th Floor Income Tax Rulings Ottawa, ON K1A 0L5 Directorate Lori Merrigan (613) 957-9229 Attention: Gilles Rochette 2012-043995 XXXXXXXXXX (the “Association”) This is in response to your correspondence of March 15, 2012, asking for our comments with respect to the tax-exempt status of the Association pursuant to paragraph 149(1)(l) of the Income Tax Act (the “Act”). ...

February 13, 2013 SME Income Tax, Audit Division Ananthy Mahendran Section 442-31, CEW-04, Sinclair 905-721-5204 VTSO Attention: Theresa Ohene-Asante A/Team Leader, Workload Development 2012-044839 Validity of Late-filed Principal Residence Election and Designation This is in response to your correspondence dated May 15, 2012, and our telephone conversation on July 5, 2012 (Mahendran / Ohene-Asante), wherein you requested our views on the validity of the principal residence election and designation in the circumstances described in your correspondence. ...

Position: Likely no Reasons: Fact specific November 21, 2012 Small & Medium Enterprises Directorate HEADQUARTERS 112 Kent Street, 19th Floor Income Tax Rulings Ottawa, ON K1A 0L5 Directorate Ann Townsend 905-721-5096 2012-045550 Attention: Rubin Dressler Non Profit Organization (“NPO”) Project- XXXXXXXXXX (the “Corporation”) This is in response to your correspondence of July 10, 2012, asking for our comments with respect to the tax-exempt status of the Corporation pursuant to paragraph 149(1)(l) of the Income Tax Act (the “Act”) for the XXXXXXXXXX and XXXXXXXXXX taxation years. ...