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Ruling
2000 Ruling 2000-0036743 - PHANTOM STOCK PLAN DIRECTORS
The Corporation will establish the "XXXXXXXXXX " (the "Plan") for the benefit of its resident and non-resident directors. ...
Technical Interpretation - Internal
5 February 1999 Internal T.I. 9826537 F - EXPRESSION CHANTIER PARTICULIER 6(6)
Cette allocation est payée sous forme d'avance mensuelle représentant un montant de XXXXXXXXXX francs belges, soit environ XXXXXXXXXX $ canadiens. 4. ...
Technical Interpretation - Internal
8 April 1999 Internal T.I. 9830997 - ATTRIBUTION - MINORS
Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...
Technical Interpretation - Internal
7 May 1999 Internal T.I. 9908197 - DEATH BENEFIT
Subsection 200(1) of the Regulations states that "Every person who makes a payment described in subsection 153(1) of the Act [...] shall make an information return in prescribed form in respect of such payment.... ...
Technical Interpretation - Internal
22 June 1999 Internal T.I. 9912437 - PAYMENTS FOR PEOPLE WITH DISABILITIES
Our Comments Assistance for Tuition/Training Costs As indicated in our memorandum of March 1, 1999, (file # 990470) paragraph 56(1)(n) of the Act requires the inclusion into income of certain scholarships, bursaries and fellowships, with a $500 exemption. ...
Ruling
1999 Ruling 9831593 - DIVISIVE REORGANIZATION
1999 Ruling 9831593- DIVISIVE REORGANIZATION Unedited CRA Tags 55(3)(a) 251(3) 251(6)(a) & (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. ...
Ruling
1999 Ruling 9919603 - EBP, EXECUTIVE SHARE PURCHASE PLAN
Any reductions of Shares acquired through the Plan will have to be approved by the Chairman & CEO of the Company, subject to the requirements of subparagraphs 4(j), (m) and (n) above. ...
Ruling
1999 Ruling 9915413 - DERIVITIVES TO MIMIC FOREIGN MUTUAL FUNDS
All payments under the forward contracts will be linked to the investment returns of the appropriate Underlying Fund and will be governed by the following terms: (a) each Fund will pay transaction costs to the Counterparty as required under the forward contract which are initially anticipated to approximate the Counterparty's bankers' acceptance rate plus approximately XXXXXXXXXX % of the nominal value of the forward contracts; (b) if the net asset value of the Underlying Fund increases, the Counterparty will pay the Fund an amount equal to the increase in the exposure under the forward contracts; and (c) if the net asset value of the Underlying Fund decreases, the Fund will pay the Counterparty an amount equal to the decrease in the exposure under the forward contract. 10. ...
Technical Interpretation - External
3 April 2019 External T.I. 2019-0797491E5 - CCA for Equipment Used to Produce Biofuels
Yours truly, Kimberley Wharram Acting Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 For the present purposes, the word “primarily” means more than 50%. 2 C.R.C. c. 945, as amended. 3 R.S.C. 1985, c. 1 (5th suppl.) as amended. 4 The following property only qualifies for an inclusion in Class 43.1: (i) mid-efficiency, fully or partially fossil-fuelled cogeneration systems; (ii) electric vehicle charging stations set up to supply more than 10 kW but less than 90 kW of continuous power; and (iii) electrical energy storage equipment connected to one of the above systems and stand-alone electrical energy storage systems meeting particular efficiency requirements. 5 See paragraphs (b) and (e) of Class 43.1. 6 During the phase-out period the enhanced CCA rates are as follows: for eligible properties that are available for use in: 2024 and 2025 the rate is 75%; 2026 and 2027 the rate is 55%; and 2028 the enhanced CCA rate is nil. 7 See generally, Tenneco Canada Inc. v The Queen, 91 D.T.C. 5207 (F.C.A.) and more recently, Canada v. ...
Technical Interpretation - Internal
10 July 2020 Internal T.I. 2020-0841961I7 - Salary Deferral Arrangements
ITRD has generally accepted that share appreciation rights (“SAR”) plans of the type described in ATR-45 – “Share Appreciation Rights Plan” would not be SDAs (“ATR-45 SAR Plans”). ...