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17 April 2003 Internal T.I. 2003-0013427 - PROPOSED GIFTING LEG.-MULTIPLE GIFTS

For example, if in a calendar year a donor makes 3 donations of $100 each to a particular registered charity and in respect of the second donation receives an article valued at $90, the eligible amount of the donor's gifts will be determined as follows: Gift #1 Gift #2 Gift #3 Property (cash) given to the charity $100 $100 $100 Advantage received 0 90 0 Eligible amount $100 $ 0* $100 *The eligible amount is zero because the amount of the advantage exceeds 80% of the FMV of the property transferred to the charity. ...

23 July 2003 Internal T.I. 2003-0028517 - COMMISSION INCOME ASSIGNED TO A CORPORATION

Serge Vallieres Income Tax Rulings Directorate Ottawa Tax Services Office Randy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2003-002851 Re: Mutual Fund Sales Reported By A Professional Corporation We are writing in response to your memorandum of July 4, 2003, wherein you inquire further to our letter of April 14, 2003 (our file 2003-000908), issued in response to your inquiry of March 18, 2003, concerning the above-noted issue. ...

31 October 2003 Internal T.I. 2003-0034757 - Non Arms Length Transfer of Shares

Yours truly, Mark Symes Corporate Reorganizations Section 1 Income Tax Rulings Directorate Policy & Legislation Branch ...

28 January 2004 Internal T.I. 2004-0054681I7 - Provincial Residency

Kiera Macfarlane Individual Client Services & Benefits Surrey Tax Centre 2004-005468 9755 King George Highway Eliza Erskine Surrey, BC January 28, 2004 Dear Ms. ...

3 June 2004 Internal T.I. 2004-0073021I7 - Commissions and paragraph 4 of IT-238R2

In its engagement letter with the advisor, the fees were calculated as follows: Acquisition 1: Fees: i) a work fee of $ XXX per month of four months...whether or not the acquisition is completed, which fee shall be credited against any fee payable under (ii) ii) a commission of.65% of the Total Transaction Value, up to a maximum of $XXX. ...

14 June 2004 Internal T.I. 2004-0074771I7 - Prohibited beneficiaries of a DPSP

In the scenario presented, Corporation A is owned by four shareholders; W owns XXXXXXXXXX % of the common shares, X owns XXXXXXXXXX% and Y and Z each own XXXXXXXXXX%. ...

19 May 2004 Internal T.I. 2004-0056491I7 - Foundation to file tax return as corp or trust?

Murphy Section Manager for Division Director International & Trusts Division Policy and Planning Branch?? ...

16 February 2005 Internal T.I. 2005-0114671I7 - Successor Pool Allocation

Christine Savage Reorganizations & Resources Industry Specialist Services Division 112 Kent Street, 13th Floor, Tower B Marc Edelson, LL.B. ...

25 February 2005 Internal T.I. 2005-0113521I7 - Artificial loss

Murphy for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

25 February 2005 Internal T.I. 2005-0113531I7 - Artificial loss