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On XXXXXXXXXX, an inspector of XXXXXXXXXX Tax Administration issued an English translation of a Declaration of residence ("XXXXXXXXXX ", "Declaration") to the effect that the Entity is a resident of XXXXXXXXXX within the meaning of article XXXXXXXXXX of the Convention for avoidance of double taxation between XXXXXXXXXX and Canada. 10. ...

January 23, 2008 HELEN PRICE HEADQUARTERS Estates & Trusts Section Income Tax Rulings Directorate Montreal TSO James Atkinson CGA Montreal, QC (519) 457-4832 Ref: 2007-025801 Qualified Small Business Corporation Shares This is in response to your email dated October 31, 2007, requesting our views concerning whether the shares of a corporation (Aco) meet the definition of "qualified small business corporation share" (QSBCS) in subsection 110.6(1) of the Income Tax Act (Act). ...

In this regard, form T2SCH 20, Part XIV – Additional Tax on Non- Resident Corporations is the schedule that computes the relevant amounts under subsection 219(1) of the Act. ...

Robin Maley Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

British Columbia (Interior Tree Fruit & Vegetable Committee of Direction) (1930); Yates v.R. (2001), 2001 CarswellNat 1369 (T.C.C. ...

For example, subparagraphs 402(4)(c)(i) and (ii) state, "if the merchandise was produced or manufactured or produced and manufactured, partly in the particular province and partly in another place by the taxpayer, …". ...

Each of these highlighted terms is defined in subsection 118.6(1) of the Act and is explained in more detail in paragraphs 1.9 – 1.25 of Income Tax Folio S1-F2-C1. ...

A "Yukon Indian Person", as defined in Chapter 1 of the UFA, is a person enrolled under one of the Yukon First Nation Final Agreements in accordance with criteria established in Chapter 3 — Eligibility and Enrollment. ...

Requirement to file a T106 The requirement to file form T106 – Information return of non-arm’s length transactions with non-residents for a particular taxation year is governed by section 233.1, which falls under Part XV of the Act. ...

" and further stating that it includes " the members of this collectively". ...