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The corporate taxpayer's XXXXXXXXXX taxation year was assessed on XXXXXXXXXX with nil tax payable and an overpayment of tax of $XXXXXXXXXX and interest of $ XXXXXXXXXX. ...

Dans la lettre d'interprétation numéro 2001-0076567, il est mentionné que les crédits pour frais de scolarité et pour études sont des déductions facultatives et que l'article 118.92 de la Loi de l'impôt sur le revenu (ci-après la "Loi ") ne transforme pas les déductions facultatives en déductions obligatoires. ...

Reasons: FITAC # E 74302. The ordinary meaning of the words "described in" used in 6(1)(b)(iii) is a reference to the categories of persons set out in 250(1)(b), (c), (d) and (d.1) and not a reference to actually being a deemed resident under those paragraphs. ...

July 11, 2002 INTERNATIONAL TAX DIRECTORATE INCOME TAX RULINGS Field & Advisory Services Unit II DIRECTORATE P. ...

September 5, 2002 WINNIPEG TAX CENTRE HEADQUARTERS Aboriginal Affairs and Attn: Brent Davies Non-Profit Section Enquiries & Adjustment Division (613) 957-8953 2002-015625 Status Indian- Medical Care Services This is in reply to your memorandum of August 8, 2002, wherein you requested our views as to whether the amounts paid by a status Indian to his mother for medical services would be exempt from income taxes under paragraph 81(1)(a) of the Income Tax Act (the "Act") and section 87 of the Indian Act. ...

File # 972976 which you refer to in your memorandum deals with a different issue. ...

Conclusion As the effect of the above described amendment to subparagraph 66(4)(b)(i) of the Act was to confirm the above long-standing position of the Department / Agency regarding the interpretation of that provision of the Act, we would not recommend that you follow the position taken in the Opinion. ...

Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

January 24, 2003 London Tax Services Office HEADQUARTERS Morris Zambon Bob Naufal, CMA Verification & Enforcement Division (613) 957-2744 2002-017628 1) Cost of Labour for M&P profits calculation 2) Revenue and salaries and wages paid by a partnership for purpose of Reg. 402(6) We are writing in response to your memorandum dated November 26, 2002, wherein you requested our interpretation of the phrase "fiscal period ending in or coinciding with" a taxation year in the circumstances described below. ...

Doug Williams HEADQUARTERS Toronto Centre Tax Services Office Randy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2002-017767 Terminal Loss Deduction on Rental Properties We are writing in response to your memorandum of December 5, 2002, wherein you requested our opinion on the above-noted issue. ...