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Current CRA website

Chapter History S1-F2-C3, Scholarships, Research Grants and Other Education Assistance

. ¶3.82 has been revised to delete previous wording that may have suggested that the deduction under paragraph 110(1)(g) is limited to tuition assistance that is received in connection with adult basic education. ¶3.82.1 has been added to provide examples of the types of training assistance to which the deduction under paragraph 110(1)(g) may apply. ... However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... This amendment was made by 2007, c. 2, s. 6(3), effective for the 2006 and subsequent tax years, to increase the $3,000 exemption to an unlimited exemption where scholarship income was received in connection with an educational program that qualified under subsection 118.6(2). ¶3.91 (formerly included in ¶43 of IT-75R4) has been revised to reflect the amendment to paragraph 56(3)(a) to effectively extend (i) to the preceding and following years. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Ruling

2009 Ruling 2008-0304371R3 - Single-Wing Butterfly

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (vi) the subject of a ruling previously issued to a taxpayer involved or a related person. ...
Ruling

2008 Ruling 2007-0251681R3 - Butterfly and freeze of an estate

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayer or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a related person; (c) under objection by the above-referenced taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2000 Ruling 2000-0003253 - Safe income

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2012 Ruling 2011-0416001R3 - Split-up butterfly

To the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is (i) in an earlier return of the above-referenced taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a related person; (iii) under objection by the above-referenced taxpayer or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2012 Ruling 2010-0376811R3 - Greenhouse Gases Act

You have advised us that to the best of your knowledge and that of the responsible officers of the Entities, none of the issues raised in this ruling are: (a) identified in an earlier tax return of the Entities or of a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Entities or of a related person; (c) under objection by the Entities or by a related person; (d) before the courts; or (e) the subject of a ruling previously considered by the Income Tax Rulings Directorate of the Canada Revenue Agency, in relation to the above-noted taxpayers or a related person. ...
Ruling

17 October 2012 Ruling 2010-0376681R3 - Internal reorganization - 55(3)(a)

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (i) dealt with in an earlier return of the above-referenced taxpayer, or a related person, (ii) being considered by a Tax Services Office or Taxation Centre in connection with a previously filed tax return of the above-referenced taxpayer or a related person, (iii) under objection or appeal by the above-referenced taxpayer, or a related person, (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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