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July 13, 2011 Small & Medium Enterprises Directorate HEADQUARTERS Specialty Audit Section Income Tax Rulings Directorate Attention: Rubin Dressler E. ...

November 8, 2011 Policy & Legislative Research Taxpayer Services and Debt Management Branch Income Tax Rulings Attention: MaryAnn McNulty Directorate Shelley Helmer (613) 957-2118 2011-041753 Exemption for XXXXXXXXXX Retiree Medical Benefits Trust This is in response to your email of August 5, 2011 wherein you inquired whether XXXXXXXXXX Retiree Medical Benefits Trust (the "RMB Trust") qualifies for an exemption from Canadian taxation pursuant to paragraph 2 of Article XXI of the Canada-United States Tax Convention (the "Convention"). ...

MEMORANDUM NOTE DE SERVICE DATE November 22, 2011 TO Kitchener Tax Services Office FROM Income Tax Rulings Directorate À DE Ontario Corporate Tax Division Bonnie Ruttan-Morillo Attention: Helen Zelobowski FILE 2011-041557 DOSSIER SUBJECT: Ontario Manufacturing & Processing ("M&P") Tax Credit and Ontario OBJET: Capital Tax Credit for Manufacturers This is in reply to your email dated July 28, 2011, regarding a corporation's eligibility for the Ontario M&P income tax credit and the Ontario capital tax credit for manufacturers where the corporation's activities consist solely of scientific research and experimental development ("SR&ED"). ...

Subsection 49(7) of the TA provides the formula to calculate the adjusted Ontario SR&ED incentive balance as: (M- N- P) / C The variable "M" is the "adjusted gross federal investment tax credit" at the end of the 2008 taxation year. ...

.), at ¶ 20. Those provisions do not permit a refund of an overpayment of tax, rather they give the Minister the discretion to re-appropriate an amount from one debt to another. ...

According to the terms of the arrangement, the employee received 80 % of his usual salary for four years, deferring 20% each year for four years to be received in the fifth year (the "Sabbatical Year"). ...

9 August 2011 Internal T.I. 2011-0410301I7- Offset of Post-Bankruptcy Refunds Unedited CRA Tags s. 152(1), 159(3), 160(1), 164(2), 224(4), 227(4), & (4.1) ITA; 227.1(1); s. 270(4), 317(7), 323(1), 325(1) ETA; s. 67(1)(c), 97(3) BIA Principal Issues: Whether a refund for the calendar year of a bankruptcy can be offset? ...

27 July 2010 Internal T.I. 2010-0374771I7- Notice of Assessment Bearing Mistaken Information Unedited CRA Tags s. 128.1(1); s. 152((1), (3), (3.1), & (4) Principal Issues: Whether mistaken information on a notice of assessment is fatal to its legal effectiveness. ...

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The information that you have provided to us indicates that the Employee is entitled to take a XXXXXXXXXX month sabbatical leave at XXXXXXXXXX % of his full-time salary after XXXXXXXXXX years of creditable service at the University. ...