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Technical Interpretation - External

11 January 2008 External T.I. 2007-0259051E5 - Foreign Spin-off

You asked us if any gain or loss or any amount is required to be included in computing your income in connection with these transactions. ...
Technical Interpretation - External

6 November 2007 External T.I. 2007-0239881E5 - Funding of a retirement compensation Arrangement

" In general, subsection 248(1) of the Act defines an RCA as a plan or arrangement under which contributions are made by an employer of a taxpayer in connection with benefits that may be provided to the taxpayer or another person, after the retirement or the loss of employment of the taxpayer. ...
Technical Interpretation - External

7 February 2008 External T.I. 2007-0234891E5 - Employee Car Allowances; Gas Expenses

We note that as explained in ¶42 of IT-522R, subparagraph 6(1)(b)(x) of the Act deems an allowance not to be reasonable if it is not based solely on the number of kilometres for which the automobile is used in connection with or in the course of performing the duties of employment. ...
Technical Interpretation - External

17 March 2008 External T.I. 2007-0239391E5 - Northern Travel Deduction

Generally, the deduction in respect of employee travel expenses provided in paragraph 110.7(1)(a) of the Act offsets the income inclusion in respect of benefits provided by an employer to an employee or the employee's family with respect to trips made for the purpose of obtaining necessary medical services not available locally or with respect to traveling expenses in connection with not more than two other trips per year subject to certain limitations. ...
Technical Interpretation - External

25 May 2006 External T.I. 2005-0164991E5 - Employer-provided vehicle

Such distance would be considered travelling in connection with or in the course of the employee's office or employment for the purposes of computing a standby charge and operating benefit. ...
Technical Interpretation - External

28 September 2006 External T.I. 2006-0188391E5 - Interest Free Loan - Life Lease

If you have a proposed transaction, we would be prepared to review it in connection with a request for an advance income tax ruling and provide a definite opinion on the tax consequences that you wish us to confirm. ...
Technical Interpretation - External

13 December 2006 External T.I. 2006-0189561E5 - Deduction by an estate for attendant care expenses

Disability Supports Deduction Generally speaking, and subject to certain limitations, the disability supports deduction permits a taxpayer to deduct from income for a year the amount of specified disability supports expenses paid in the year to enable the taxpayer to earn income from an office or employment, from business or from conducting research in connection with a grant received for that purpose. ...
Technical Interpretation - External

15 December 2006 External T.I. 2006-0213071E5 - Eligible Capital Property Acquisition

Assuming that the issuance of shares by a parent to its subsidiary is not contrary to the applicable corporate law, and that the other conditions of subsection 85(1) are met, the goodwill could be transferred, in connection with a disposition of a business, from OLDCO to NEWCO at an elected "agreed amount". ...
Technical Interpretation - External

12 July 2005 External T.I. 2004-0092961E5 - Personal credits in different provinces-Bankruptcy

July 12, 2005 Dear XXXXXXXXXX: Re: Non-Refundable Tax Credits in Year of Bankruptcy We are writing in reply to your enquiry of August 27, 2004, requesting our comments in connection with the calculation of certain provincial non-refundable tax credits in the year an individual becomes a bankrupt. ...
Technical Interpretation - External

30 May 2005 External T.I. 2005-0114411E5 - Taxability of Bursary

$3,000 when the amounts included under subparagraph 56(1)(n)(i) are in respect of a scholarship, fellowship or bursary received in connection with the taxpayer's enrolment in an educational program for which he or she may claim an education tax credit for the year... ...

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