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30 April 1999 Technical Interpretation RITS HQR001701-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) "... ...

.- Q. 27-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Foreign travel expenditures, including remuneration, will generally be allowed if they are directly attributable to R & D carried on in Canada. ...

.- Q. 27-- summary under Subsection 2900(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2900- Subsection 2900(2) Each employee's employment duties must be examined and a determination made as to whether his duties directly relate to the undertaking, supervision or support of R & D. ...

IT-506 "Foreign Income Taxes as a Deduction From Income" 5 January 1987-- summary under Subsection 104(22) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(22) … Since the rules in subsection 104(22) apply only to that subsection and to section 126, a beneficiary may not utilize the provisions of subsection 20(11) or (12) in respect of foreign taxes allocated to it under subsection 104(22). ...

ATR-69, dated April 20, 1995-- summary under Subparagraph 212(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Subparagraph 212(1)(b)(vii) Favourable ruling given with respect to a requirement to repurchase 10-year notes at 101% of their principal dollar amount in the event of the occurrence both of a change of control (as defined) and a ratings downgrade by Moody's or Standard & Poor's. ...

Situation D-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Revenues 4.9:1 1.6:1 13.5:1 0.5:1 Assets 5.6:1 1.1:1 21.0:1 0.5:1 # of Employees 4.0:1 1.6:1 38.8:1 0.1:1 To date… Rulings has not denied the availability of treaty benefits under Article XXIX-A(3) on the determination that the US business was not substantial in comparison to the Canadian activities. ...

IC 72-17R6 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada- Section 116"-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "... ...

. … It is expected that the CRA will announce formal changes to the program in the fall of 2017. ...

Canada Emergency Wage Subsidy (CEWS) Calculator under Who is an eligible employer, 21 April 2020 CRA Webpage-- summary under Qualifying Revenue Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Revenue What is an eligible revenue reduction … Use your normal accounting method when calculating revenue. ...

Canada Emergency Wage Subsidy (CEWS) Calculator under How to apply, 21 April 2020 CRA Webpage-- summary under Subsection 125.7(6) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(6) Incorrect or fraudulent claims … If you artificially reduce your revenue for the purpose of claiming the wage subsidy you will be required to repay any subsidy amounts you received plus a penalty equal to 25% of the total value. ...