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Ruling
2007 Ruling 2006-0211991R3 - Part XIII Tax
Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External
19 May 2009 External T.I. 2007-0263441E5 - Tax Treaties
Yours truly, Daryl Boychuk Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal
20 November 2008 Internal T.I. 2008-0281411I7 - Addition of Beneficiaries
Robin Maley Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Conference
25 September 2012 Roundtable, 2012-0457611C6 - BC Tax Conference 2012 Question #5
In Interpretation Bulletin 83R3, Non-profit organizations Taxation of income from property, CRA has also take the position that rental income can be income from property or income from business, depending upon whether the rents were derived from one of the main activities of the club or ancillary to the activities of the club. ...
Technical Interpretation - External
20 November 2014 External T.I. 2013-0474101E5 - NPO wind-up - asset distribution
Messore (613) 948-2227 2013-047410 November 20, 2014 Dear XXXXXXXXXX: Re: Paragraph 149(1)(l) of the Income Tax Act and capital gains This is in response to your email interpretation requests regarding a client ("entity ") that considers its income to be exempt from income tax pursuant to paragraph 149(1)(l) of the Income Tax Act. ...
Technical Interpretation - Internal
23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit
British Columbia (Interior Tree Fruit & Vegetable Committee of Direction) (1930); Yates v.R. (2001), 2001 CarswellNat 1369 (T.C.C. ...
Ruling
2015 Ruling 2015-0570291R3 - Foreign tax credit on income from a trust
Yours truly, XXXXXXXXXX For Director Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External
16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise
Yours truly, Randy Hewlett Director International Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Technical Interpretation - External
26 January 2015 External T.I. 2014-0545051E5 - Subsections 98(1) and 98.1(1)
Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External
17 June 2014 External T.I. 2013-0506731E5 - Immigration
Your view is that upon the declaration of the dividend by NRCo a "debtor creditor" relationship arises between NRCo and the shareholder and as a result, in Scenario 1, the amount paid by NRCo to the shareholder after the Immigration Day should not be considered a dividend, but should rather be considered a payment to discharge the debt claim arising as a result of the declaration of the dividend. ...