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Raisons POUR POSITION ADOPTÉE: 1- notes techniques du ministère des Finances (Bill c-59) sur les modifications apportées au paragraphe 127(11.2) de la Loi 2- principe d'interprétation, version anglaise et dossier CCM # 9504518 3- logique de la règle transitoire Le 11 janvier 1996 BUREAU DES SERVICES FISCAUX ADMINISTRATION CENTRALE DE RIMOUSKI Direction des décisions et de l'interprétation A l'attention de M. ...

Suite à une conversation téléphonique (Lalonde\ Bouffard) le 9 janvier 1996, Madame Lalonde nous a demandé de leur confirmer si les activités de " XXXXXXXXXX" sont incluses dans la définition du terme «agriculture» au sens du paragraphe 248(1) de la Loi de l'impôt sur le revenu (ci-après la «Loi»). ...

When #CO redeemed the shares, the individual would have had a deemed dividend of: $XXXXXXXXXX (redemption amount)- $XXXXXXXXXX (PUC) = $XXXXXXXXXX. ...

Serge Vallieres HEADQUARTERS Ottawa Tax Services Office Randy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2003-000908 Mutual Fund Sales Reported By A Professional Corporation We are writing in response to your memorandum of March 18, 2003, wherein you asked for our opinion on a situation in which a corporation reported the commission income earned from mutual fund sales that were made by its individual shareholder. ...

Reasons: Information provided by Trust Accounts Division (formerly Source Deductions) of Assessment & Collections Branch June 16, 2003 CALGARY TSO HEADQUARTERS Income Tax Rulings Attention: Tanya Agecoutay Directorate Renée Shields (613) 948-5273 2003-001480 Withholding taxes on payments to status Indians from registered vehicles This is in response to your facsimile of April 23, 2003 seeking our comments on the Canada Customs and Revenue Agency's ("CCRA") requirements in order to waive withholding taxes when payments are made to a status Indian from a registered retirement savings plan ("RRSP") or registered retirement income fund ("RRIF") where the RRSP/RRIF amount originated from a registered pension plan ("RPP") benefit arising from tax-exempt employment income. ...

Other comments As provided in our file # 2000-0036547, "the recapture provisions of the Act and Regulations are fundamentally adjustments to income of previous years and do not create, in the year of disposal of the asset, some new form or source of income". ...

September 4, 2003 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Tax Services Office Rrandy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2003-000976 Subsection 1101(5d) of the Income Tax Regulations (the "Regulations") We are writing in response to your memorandum of March 24, 2003, wherein you asked for our opinion on an issue involving a taxpayer's classification of railway cars pursuant to the above-noted provision. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

We are only able to provide definitive comments on the income tax implications that may arise when transactions occur between persons not dealing with each other at arm's length in the context of a particular fact situation Therefore, when employment is ruled not insurable because the persons are considered not to be dealing with each other at arm's length at a particular time, and there is some concern that this decision could also have income tax implications, then the issue should be discussed with a technical advisor in the Verification & Enforcement Division ("V&E") of the applicable tax services office. ...

November 17, 2003 XXXXXXXXXX TSO HEADQUARTERS XXXXXXXXXX Income Tax Rulings Verification & Enforcement Division Directorate Randy Hewlett, B.Comm 613-957-8973 2003-004678 Application Of Subsection 20(7)- Software Maintenance Plans We are writing in response to your e-mail of November 3, 2003, wherein you provided us with a copy of a letter from XXXXXXXXXX (the "Taxpayer"), submitted to you in response to our memorandum of October 7, 2003 (our file 2003-003794). ...