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Technical Interpretation - Internal
22 January 2015 Internal T.I. 2014-0560571I7 - Paid-up capital reduction of a foreign affiliate
At the time of the investment, the exchange rate was $1US = $1 Canadian. ...
Technical Interpretation - Internal
24 December 2015 Internal T.I. 2014-0560831I7 - International shipping
The Taxpayer’s activities carried on in Canada consist primarily of XXXXXXXXXX, in order to satisfy the shipping requirements of certain related companies – XXXXXXXXXX (the “Related Party Customers”) XXXXXXXXXX. 3. ...
Technical Interpretation - Internal
9 March 2016 Internal T.I. 2015-0612501I7 - ITA 261(21) anti-avoidance
Either the non-resident corporation does not have a tax reporting currency, or it has the Canadian dollar tax reporting currency – the same as the Canadian-resident corporation. ...
Technical Interpretation - Internal
28 May 2012 Internal T.I. 2011-0421441I7 - Travel btwn temp residence and special work site
May 28, 2012 Ita Mackey Tom Posadovsky, CMA Trust Exam & Employer Compliance Audit IT Rulings Directorate Newfoundland and Labrador Tax Services Office Reorganizations Division Sir Humphrey Gilbert Building 165 Duckworth Street, PO Box 12075 (613) 952-8283 St. ...
Technical Interpretation - Internal
22 March 2012 Internal T.I. 2011-0412051I7 - Application of Subsection 149(5)
Specifically: It describes the purposes of the Corporation as "to encourage the instruction, practice, enjoyment and advancement of its members in all aspects of XXXXXXXXXX in accordance with the XXXXXXXXXX ". ...
Technical Interpretation - Internal
10 November 2011 Internal T.I. 2011-0410851I7 - Paragraph 149(1)(l)
The members live together in a building owned by a charity (the "XXXXXXXXXX "). ...
Technical Interpretation - Internal
5 April 2011 Internal T.I. 2011-0395551I7 - Clergy residence deduction
As stated in the incoming, the following describes the duties of the Individual as a campus minister: "XXXXXXXXXX " The incoming further lists the following as some of the specific duties performed by the Individual: Preach and teach on spiritual and theological subjects. ...
Technical Interpretation - Internal
7 April 2011 Internal T.I. 2010-0380581I7 - Paragraph 149(1)(l) of the Income Tax Act
April 7, 2011 Tactical Intelligence & Informant Leads HEADQUARTERS Compliance Programs Branch Income Tax Rulings Directorate Attention: Rhéal Dorval, Manager L. ...
Technical Interpretation - Internal
21 June 2011 Internal T.I. 2010-0379561I7 - Condominium Corporation--149(1)(l)
June 21, 2011 Small & Medium Enterprises Directorate HEADQUARTERS Income Tax Rulings Attention: Rubin Dressler Directorate L. ...
Technical Interpretation - Internal
23 July 2010 Internal T.I. 2010-0374761I7 - Section 160 and Multiple Transfers of Property
23 July 2010 Internal T.I. 2010-0374761I7- Section 160 and Multiple Transfers of Property Unedited CRA Tags s. 152(3) & (8), 160 Principal Issues: Whether one assessment can be used to encompass a number of transfers of property. ...