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Technical Interpretation - External
17 January 2007 External T.I. 2005-0152601E5 F - Politique d'application RS & DE 1996-02
17 January 2007 External T.I. 2005-0152601E5 F- Politique d'application RS & DE 1996-02 Unedited CRA Tags 37(1) 37(2) 127 REG 2900 Principales Questions: Quelle est la pertinence de la politique d'application 1996-02 de l'Agence du revenu du Canada en matière de RS & DE à la lumière des arrêts Canada c. ... XXXXXXXXXX 2005-015260 Le 17 janvier, 2007 Monsieur, Objet: Demande d'interprétation technique: Politique d'application en matière de______recherche scientifique et de développement expérimental ("RS & DE")_______ La présente fait suite à votre courriel en date du 28 septembre 2005 par lequel vous demandez notre opinion concernant le sujet ci-mentionné. ... Lorsque le projet est mené à l'extérieur du Canada, le contribuable n'a pas effectué de la RS & DE au Canada. ...
Technical Interpretation - External
15 June 2006 External T.I. 2006-0183921E5 - Definition of Canada & Reg.105
15 June 2006 External T.I. 2006-0183921E5- Definition of Canada & Reg.105 Unedited CRA Tags 255 Reg.105 Principal Issues: (1) Whether the work done by NRco could be considered to be "in connection with the exploration for or exploitation of the minerals... ... Question 1 1-) Section 255 of the Act & Section 105 of the Regulations The term " Canada" is not defined in the Income Tax Act. ... The Queen (2005 TCC 769), Judge Miller explored the issue of what is meant by "exploitation" for the purposes of the Overseas Employment Tax Credit (the "OETC"). ...
Ruling
2013 Ruling 2013-0488661R3 - Indian Band -Public Body & Function of Government
2013 Ruling 2013-0488661R3- Indian Band-Public Body & Function of Government CRA Tags 149(1)(c) Principal Issues: Is the XXXXXXXXXX a public body performing a function of government within the meaning of 149(1)(c) and therefore exempt from income tax on the interest income received from a GIC? ... XXXXXXXXXX 2013-048866 XXXXXXXXXX, 2013 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-named taxpayer. ... DEFINITIONS In this letter unless otherwise expressly stated: a) "Band Council" has the meaning assigned to it in Paragraph 6; b) "CRA" means Canada Revenue Agency; c) "FNFSM Act" means First Nations Fiscal and Statistical Management Act, S.C. 2005, c.9; d) "GIC" has the meaning assigned to it in Paragraph 24; e) "Indian Act" means the Indian Act, R.S.C, 1985, c. ...
Ruling
2008 Ruling 2008-0295711R3 - Indian Band-Public Body & Function of Government
2008 Ruling 2008-0295711R3- Indian Band-Public Body & Function of Government Unedited CRA Tags 149(1)(c) Principal Issues: Is the Indian band a public body performing a function of government? ... The Indian Band has established laws in relation to the taxation of real property pursuant to the First Nations Fiscal and Statistical Management Act, S.C. 2005 c.9 (the "FSMA"). ... This GIC will earn interest at a rate of XXXXXXXXXX %. Purpose of the Proposed Transaction The purpose of the proposed transaction is to generate additional income for the Indian Band to fund and support the governance, public works, infrastructure, social services and general development of the Indian Band. ...
Scraped CRA Website
ARCHIVED - Schedules – Certain Assets Used in Petroleum and Natural Gas Activities
ARCHIVED- Schedules – Certain Assets Used in Petroleum and Natural Gas Activities We have archived this page and will not be updating it. ... New ¶ 28 provides a discussion about assets included in the new schedules appended to the bulletin. ¶s 29-30 (a portion of former ¶ 4) describe certain property that is excluded from depreciable property. ¶ 31 (former ¶ 2) has been revised to include the legislative amendments to the definitions of CEE and CDE that specifically exclude depreciable property from being CEE or CDE. ...
Archived CRA website
ARCHIVED - Schedules – Certain Assets Used in Petroleum and Natural Gas Activities
ARCHIVED- Schedules – Certain Assets Used in Petroleum and Natural Gas Activities From: Canada Revenue Agency We have archived this page and will not be updating it. ... New ¶ 28 provides a discussion about assets included in the new schedules appended to the bulletin. ¶s 29-30 (a portion of former ¶ 4) describe certain property that is excluded from depreciable property. ¶ 31 (former ¶ 2) has been revised to include the legislative amendments to the definitions of CEE and CDE that specifically exclude depreciable property from being CEE or CDE. ...
Old website (cra-arc.gc.ca)
Chapter History - S3-F10-C1, Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs
Chapter History S3-F10-C1, Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs Introduction The purpose of this Chapter History page is to highlight any amendments to the information contained in an interpretation bulletin that is now reflected in a chapter of an income tax folio as well as to identify any subsequent amendments to a folio chapter. ... Update September 2, 2016 General Income Tax Folio S3-F10-C1, Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs, replaces and cancels Interpretation Bulletin IT-320R3, Qualified Investments – Trusts Governed by Registered Retirement Savings Plans, Registered Education Savings Plans and Registered Retirement Income Funds. ... The debt obligation discussed in former ¶10(h) of IT-320R3 is now covered by the general rule for investment-grade debt. ¶1.31 is added to provide information about prescribed credit rating agencies, which are relevant for investment-grade debt discussed in ¶1.30 (new subsection 4900(2) added by S.C. 2007, c. 29, ss. 32(6), applicable in determining qualified investment status after March 18, 2007). ¶1.32- 1.36 (formerly ¶11 and ¶12 of IT-320R3) have been revised to reflect amendments to paragraphs 4900(1)(j) and (j.2) of the Regulations (made by P.C. 2005-1508, ss. 6(3) and (9), August 31, 2005, Canada Gazette, Part II, September 21, 2005, applicable to property acquired after February 27, 2004 and applicable after 2006 to property acquired before February 28, 2004), the main effect of which was to add a requirement that arm’s length mortgages be fully secured. ¶1.34 and ¶1.35 have been expanded to provide additional information on situations where the registered plan trustee takes action to protect the mortgage investment and where the trustee does not. ¶1.36 has been revised to replace the reference to “insured under the National Housing Act ” with a reference to “insured by the Canada Mortgage and Housing Corporation” since only CMHC is authorized to insure mortgages under that Act. ¶1.38- 1.44 (formerly ¶21- 23 of IT-320R3) have been revised to reflect amendments to paragraphs 4900(1)(e) and (e.01) of the Regulations (made by P.C. 2005-1508, ss. 6(5), August 31, 2005, Canada Gazette, Part II, September 21, 2005, generally applicable after February 27, 2004). ...
Technical Interpretation - External
19 December 2006 External T.I. 2006-0189491E5 - Revised carryback & Interest computations
19 December 2006 External T.I. 2006-0189491E5- Revised carryback & Interest computations Unedited CRA Tags 161(1) 161(7) 152(6) 111 Principal Issues: Where in year 3 by virtue of ss.152(6), the taxpayer requests a reduction of tax for year 1 by means of a loss carryback from year 3 to year 1, but then subsequently in year 5, revises the request in order to increase the loss carryback from year 3 to year 1, would the interest charged pursuant to subsections 161(1) and (7) be charged on the combined reduction up to the date of the later request, or would interest be charged on each reduction separately up to the date of each respective request? ... XXXXXXXXXX 2006-018949 Tim Fitzgerald, CGA December 19, 2006 Dear XXXXXXXXXX: This is in reply to your correspondence of March 23, 2005 wherein you requested our comments regarding interest computations under subsections 161(1), (2) and (7) of the Income Tax Act ("the Act") and also asked us for our views regarding a nil assessment. ... In respect of Scenario A, you seem to be concerned that the subsequent request for loss carryback made in year 5 may reset the interest calculation date under paragraph 161(7)(b) for the total tax reduction resulting from all amounts carried back (i.e., $500 + $500) from year 3 to year 1 so that interest is payable on the entire $400 of reduction of tax payable for the period from the balance-due day of year 1 to the day that is 30 days after the day in which the latest carry back request was made in year 5, pursuant to subparagraph 161(7)(b)(iv). ...
Old website (cra-arc.gc.ca)
CRA Annual Report to Parliament 2007-2008 - Canada Revenue Agency Financial Statements – Administered Activities
Canada Revenue Agency Financial Statements – Administered Activities Previous page Next page Canada Revenue Agency Notes to the Financial Statements – Administered Activities 1. ... The CCRA Act was amended on December 12, 2005 and renamed the Canada Revenue Agency Act (CRA Act). ... As well, effective August 1, 2005 the Agency provides to the department of Human Resources and Social Development Canada (HRSDC) collection services for certain accounts receivable under various acts. ...
Current CRA website
Child Benefits – Retroactive Eligibility of Foreign-Born Status Indians
Child Benefits – Retroactive Eligibility of Foreign-Born Status Indians Notice to the reader This measure has received Royal Assent. ... Starting with benefits applicable to January 2005, the budget proposes that these individuals be made retroactively eligible for the CCTB, the NCBS and the UCCB, where all other eligibility requirements are met. 2. ... You can refer to Canada child benefit – Before you apply on Canada.ca to see if you are eligible because the eligibility rules for the CCTB, the NCBS and the UCCB are the same as those for the CCB. 4. ...