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11 May 2009 External T.I. 2008-0276761E5 F- Class 43.1 and 43.2-- summary under Eligible Waste Fuel Summary Under Tax Topics- Income Tax Regulations- Regulation 1104- Subsection 1104(13)- Eligible Waste Fuel wood pellets are wood waste In the course of describing how a wood waste fuelled heat production system and ground source heat pump might qualify for inclusion in Class 43.2, CRA stated: According to NRCan, wood pellets are "wood waste" for the purposes of the definition of "eligible waste fuel" …. ...

3 July 2007 External T.I. 2007-0236551E5 F- Crédit d'impôt pour études-- summary under Qualifying Student Summary Under Tax Topics- Income Tax Act- Section 118.6- Subsection 118.6(1)- Qualifying Student post-doctoral fellow is not a student Regarding whether a post-doctoral fellow entitled to the education tax credit under s. 118.6(2) in respect of the fellowship, CRA stated that “to be eligible for the education tax credit … the individual must be a student and enrolled in an educational program,” before finding that a fellow did not so qualify. ...

CRA responded: [A]s stated in … IT-131R2 [para. 1] a convention may be defined as a formal meeting of members of an organization for professional or business purposes. ...

CRA indicated this is not required under the Act, but invoices remain proof of income tax liability thereunder – and, in this regard, referred to various statements in IC-78-10R4. ...

22 March 2005 External T.I. 2004-0098591E5 F- Application de l'alinéa 212(9)d) proposé-- summary under Paragraph 212(9)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(9)- Paragraph 212(9)(d) extension to provincial regulatory authority under review CRA indicated that the exemption as then worded did not apply if a provincial rather than federal authority was the party to the reinsurance indenture – but this matter was under consideration by Finance. ...

31 May 1994 External T.I. 9406165- FARMING BUSINESS-- summary under Farming Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Farming grain drying "... ...

22 October 1996 External T.I. 9630315- SBC- ONLY ASSET INTEREST IN A PARTNERSHIP-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation "... ...

6 January 2005 External T.I. 2004-0088791E5 F- Paragraphe 4803(2) du Règlement-- summary under Subsection 4803(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 4803- Subsection 4803(2) Reg. 4803(2) satisfied if any of its paragraphs is satisfied CRA indicated, based on the meaning of “or”: [T]he conditions listed in paragraphs 4803(2)(a) to (d) … are not cumulative. ...

20 June 2001 External T.I. 2001-0086505 F- RPEB- MONTANTS PERDUS-- summary under Subsection 144(9) Summary Under Tax Topics- Income Tax Act- Section 144- Subsection 144(9) s.144(9) inapplicable until employee ceases to be a beneficiary CCRA indicated that where the employee forfeits a conditional allocation of shares and remains a beneficiary under the EPSP, s.144(9) will not apply – but will apply in respect of such forfeited allocation when the individual ceases to be a beneficiary. ...

23 August 2001 External T.I. 2001-0086235 F- CONVENTIONS FISCALES A.18-- summary under Subparagraph (a)(ix) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Income Tax Conventions Interpretation Act- Section 5- Pension- Paragraph (a)- Subparagraph (a)(ix) OAS and QPP payments were “pension” payments Regarding the tax treatment of QPP and OAS payments made to residents of Slovenia, CCRA indicated that under the Slovenia Convention, since “pension” was not defined, its meaning under s. 5 – pension- (a)(ix), of the ICTCIA applied to render them pension payments. ...