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Specifically, you refer to the comments in paragraph 6 of Interpretation Bulletin IT-268R4, Inter Vivos Transfer of Farm Property to Child which states in part: "... subsection 73(3) applies only to property owned by the parent immediately before the transfer to a child and thus is not applicable to property owned at that time by a partnership or corporation." Our Comments: Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

OUR COMMENTS Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... For Director International & Trusts Division Income Tax Rulings Directorate Legislative and Regulatory Affairs Branch ENDNOTES 1 It is our understanding that an individual will be considered an Israeli resident if the individual's center of life is in Israel. ...

. $500,000- (275,000) = $775,000]. In other words, it is your interpretation that the "negative ACB" of the partnership interest would increase the available "bump" room. You have requested that we provide our comments regarding the aforementioned analysis and interpretation of the calculation in paragraph 88(1)(d). 3) Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

Depends on facts-- but generally yes Reasons: 2. as long as all the requirements are met & taxpayer claims CCA on cost net of grant per 13(7.1) XXXXXXXXXX 2008-030133 Lena Holloway January 15, 2009 Dear XXXXXXXXXX: This is in response to your electronic mail of November 21, 2008, wherein you requested our comments in respect of class 43.2 of Schedule II of the Income Tax Regulations (the "Regulations"). ... Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

For more information about how to obtain a ruling, please refer to Information Circular 70-6R5, Advanced Income Tax Rulings, dated May 17, 2002. ... Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

The scenario can be summarized as follows: Husband (H) & Wife (W) are living separate and apart as a result of a breakdown in their marriage. ... Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...

Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... The answer is "no," as confirmed in paragraph 24 of IT-268R4, which states, in part: Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming.... ...

Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Un particulier est propriétaire de plusieurs immeubles locatifs qui ont un coût supérieur à 50 000 $. ... Nos commentaires Tel qu'il est mentionné au paragraphe 22 de la Circulaire d'information 70-6R5 du 17 mai 2002, l'Agence du revenu du Canada (ARC) a comme pratique de ne pas émettre d'opinion écrite concernant des transactions projetées autrement que par voie de décisions anticipées. ...

Pursuant to the terms of the Collective Agreement, a Service Contractor is required to contribute XXXXXXXXXX% of the gross compensation paid to a Member (referred to as an "Insurance Contribution") and another XXXXXXXXXX % of the gross compensation paid to a Member (referred to as a "Retirement Contribution") to the Union when the particular Service Contractor engages the services of a Member. ... Our Comments: Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...