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21 November 1994 Internal T.I. 9418117- TUITION & EDUCATION T. C. ... Principal Issues: whether tuition tax credit & education tax credit are available in respect of a university that is NOT designated under the Canada Student Loans program Position TAKEN: yes for both credits Reasons FOR POSITION TAKEN:-tuition tax credit-position stated in IT-516R-education tax credit- November 21, 1994 XXXXXXXXXX DISTRICT OFFICE Rulings Directorate XXXXXXXXXX A. ... While it is unlikely that subsection 118.6(1) of the Act was intended to deny a full time university student an education tax credit because of the lack of designation by the provincial authorities, a strict interpretation of the definition of "designated educational institution" in subsection 118.6(1) would suggest that a university or college which is not "... designated by the Lieutenant Governor in Council of a province as a specified educational institution under the Canada Student Loans Act, designated by an appropriate authority under the Canada Student Financial Assistance Act, or designated by the Minister of Higher Education and Science of the Province of Quebec for the purposes of An Act respecting financial assistance for students of the Province of Quebec... ...

30 June 1995 Internal T.I. 9514457- special purpose trust & taxable benefit from a trust Unedited CRA Tags 105(1) 149(1)(l) 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. ... Would payments made to the parent or guardian of a minor for trust approved expenses (for health, welfare, security & education) be taxable to the parent/guardian under 105(1)? ... Depending on the nature of the governing document, & if not set up to benefit public at large, it would not qualify as either a charity or NPO. ...

30 November 2012 Internal T.I. 2012-0458491I7- Private School – Non-profit organization CRA Tags 149(1)(l) Principal Issues: Does the entity qualify as a non-profit organization pursuant to paragraph149(1)(l) of the Act Position: No Reasons: The entity operates a private high school for the purpose of earning profit. November 30, 2012 Specialty Audit Section, Headquarters Specialty Audit Division IT Rulings Directorate Small & Medium Enterprises Directorate A. ... Founded in XXXXXXXXXX, the school currently has about XXXXXXXXXX students, XXXXXXXXXX % of whom are international students and the remaining XXXXXXXXXX % Canadian. 2. ...

23 January 2013 Internal T.I. 2012-0465081I7- Subsection 107(2) – a disposition by a NR Trust CRA Tags 107(2) 116 248(1) "disposition" Principal Issues: Does paragraph 107(2)(a) change the timing of the disposition for the purposes of section 116? ... Subsection 107(2) states: (2) Distribution by personal trust – Subject to subsections (2.001), (2.002) and (4) and (5), if at any time a property of a personal trust or a prescribed trust is distributed (otherwise than as a SIFT trust wind-up event) by the trust to a taxpayer who was a beneficiary under the trust and there is a resulting disposition of all or any part of the taxpayer's capital interest in the trust, (a) the trust shall be deemed to have disposed of the property for proceeds of disposition equal to its cost amount to the trust immediately before that time; (b) subject to subsection (2.2), the taxpayer is deemed to have acquired the property at a cost equal to the total of its cost amount to the trust immediately before that time and the specified percentage of the amount, if any by which… You request our views on whether paragraph 107(2)(a) deems a disposition of the property to occur immediately before the actual distribution from the non-resident trust to the beneficiary. ... The phrase "immediately before that time" as used in paragraph 107(2)(a) of the Act, qualifies only the words "... its cost amount to the trust... ...

7 November 1995 Internal T.I. 9528117- CAPITAL GAINS ELECTION & TRUSTS Unedited CRA Tags 110.6(19) 104(24) 104(13) 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. ... Where a trust is "non-discretionary" and the residual beneficiaries are required to share equally in the capital & income of the trust, is a special provision required in the trust indenture to make the 110.6(19) deemed capital gain payable to the beneficiaries? ... A preferred beneficiary election will be deemed to be filed on time where it is a direct result of and filed with a "valid late-filed capital gains election" (see page 8, item 9. of Verifications & Collections directive # ARD-95-02). ...

27 February 1995 Internal T.I. 9426687- PREJUDGEMENT INTEREST ON AWARD FOR WAGES & REINSTATEMENT Unedited CRA Tags 6(3) 5 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. ... Where an individual is reinstated, there is no loss of employment & thus any amount awarded cannot be considered as damages from wrongful dismissal February 27, 1995 Shawinigan-Sud Tax Centre Head Office T1 Client Services Rulings Directorate A. ...

17 February 2000 Internal T.I. 2000-0003357- H & W TRUST-DEDUCTION FOR ASO FEES Unedited CRA Tags 9(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. ... John Oulton Manager Business, Property & Employment Income Section Income Tax Rulings Directorate ...

7 April 1997 Internal T.I. 9633857- CLERGY HOUSING-APPOINTMENT, MINISTER & ADMINISTRATION Unedited CRA Tags 8(1)(c) 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: clergymen's residence deduction-whether charity is a religious order, who appointed clergyman to his position, meaning of the terms minister and administration Position: charity not a religious order, question of fact as to who appointed minister to administrative post, the term minister refers to spiritual leader of a religious denomination who performs all the activities including pastoral care and priestly functions, normally associated with the term, administrative service can be distinguised from groundkeeping and accounting in that the latter are specific tasks done at the direction of the administrator Reasons: 8(1)(c) status test involves issue of what is a regular minister function test required determination of whether charity is a religious order, who appointed the minister to his position as well as whether accounting & groundkeeping constituted administrative service April 7, 1997 Kitchener Tax Services Office Headquarters Business Audit A. ... Oulton Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c.: Deanna Dubé, Individual Returns & Payment Processing Directorate ...

15 May 2019 Internal T.I. 2019-0803411I7- Medical practitioners- the METC & the DTC Unedited CRA Tags 118.4(2); 118.3(a.2) and 118.3(a.3) Principal Issues: Whether the CRA can set up a process to consider requests to change (or expand) the categories of medical practitioners who can certify Form T2201, Disability Tax Credit Certificate. ... Reasons: Changes to the categories of medical practitioners who can provide certification for the purpose of the disability tax credit (DTC) would require a legislative amendment to section 118.3 – this is beyond the CRA's mandate as an administrator of the Act. ... Medical practitioners for the purposes of the DTC While subsection 118.4(2) describes the requirements for a person to be considered a medical practitioner for purposes of sections 118.2 and 118.3 (among others) – namely, the requirement to consider the relevant provincial legislation – specific rules in section 118.3 allow only certain categories of medical practitioners to certify that an individual has a severe and prolonged impairment in physical or mental functions for the purposes of the DTC. ...

28 June 1994 Internal T.I. 9407347- EQUIV TO MARRIED TAX CREDIT, NON-RES CHILD & DOUBLING OF Unedited CRA Tags 118(1)(b) 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: technical explanation of 1) the reason why one person in a on-going marriage can't claim the equivalent to married tax credit, 2) the basis for the position of allowing the most beneficial personal tax credit in the year of marital change, 3) whether daughter and father can both claim mother & 4) why 118(1)(b)(ii)(A) makes an exception for a non-resident child Position TAKEN: 1) "not entitled to" means "can't have a deduction"-it is other grounds & the scheme of the Act which prevent a taxpayer from taking a credit under (b) when s/he is married & not separated from spouse 2) it is an administrative position only 3) daughter can't claim mother 4) sojourners and non-residents who earn substantially all their income in Canada can claim equivalent to married for child living with him/her outside of Canada. ... You ask whether the phrase "... an individual not entitled to a deduction by reason of paragraph (a)... ...