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Technical Interpretation - External

18 December 2001 External T.I. 2001-0107655 - SECURITIES-INCOME VS. CAPITAL

Principal Issues: Whether an individual who deals in put and call options and in connection with those activities also buys and sells securities is carrying on a business. ...
Technical Interpretation - External

9 November 2001 External T.I. 2001-0092515 - SHAREHOLDER-MANAGER REMUNERATION

In answer to question 42 of the Round Table session, it was stated that: In general, the reasonableness of salaries and bonuses paid to principal shareholder-managers of a corporation would not be challenged when: the general practice of the corporation is to distribute the profits of the company to its shareholder-managers in the form of bonuses or additional salaries; or the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are attributable to special know-how, connections or entrepreneurial skills of the shareholders. ...
Technical Interpretation - External

3 July 2002 External T.I. 2001-0084615 - ACCEPTABLE EVENTS OF DEFAULT

Nevertheless, we offer the following general comments in connection with your request which we hope are of assistance to you. ...
Technical Interpretation - External

7 May 2002 External T.I. 2002-0127505 - SUBSTITUTE LIFE POLICIES

If sufficient detail was provided in the policy such that no negotiation or renegotiation of the terms and conditions of the policy would be required in connection with the substitution, the exercise of the right of substitution provision may not result in a disposition. ...
Technical Interpretation - External

10 July 2002 External T.I. 2002-0142545 - MORTGAGE INTEREST DEDUCTIBILITY

Generally, an individual's use of land in excess of 1/2 hectare in connection with a particular lifestyle does not, in itself, mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...
Technical Interpretation - External

28 June 2002 External T.I. 2002-0143085 - PRINCIPAL RESIDENCE

In connection with Unit B, you have asked us to consider whether it can qualify as the principal residence of the Owner. ...
Technical Interpretation - External

25 October 2002 External T.I. 2002-0151645 - INSURANCE PREMIUM REBATES

XXXXXXXXXX 2002-015164 Alison Campbell October 25, 2002 Dear XXXXXXXXXX: Re: Insurance Premium Rebates This is in reply to your letter of July 10, 2002 wherein you requested our comments on the tax implications to a policyholder who receives what you refer to as a premium rebate in connection with the purchase of a newly issued universal life insurance policy. ...
Technical Interpretation - External

29 October 2002 External T.I. 2002-0158515 - ELIGIBILITY FOR EDUCATION TAX CREDIT

Additionally, the credit will not be available if the program is taken by the student while receiving income from an office or employment and in connection with that office or employment. ...
Technical Interpretation - External

28 November 2002 External T.I. 2002-0145175 - SUPPLEMTARY PENSION FUNDING

In general terms, the provisions of the Income Tax Act (the "Act") pertaining to RCAs apply to any arrangement, whether contractual or otherwise, where contributions are made by an employer, a former employer or a person who is not dealing at arm's length with the employer, to a custodian in connection with benefits that are to be paid to a former employee on retirement or loss of employment, except in specific excluded situations. ...
Technical Interpretation - External

19 November 2002 External T.I. 2002-0169825 - EXEMPTION OF INDIAN EMPLOYMENT INCOME

It also requires that the employer is an Indian band which has a reserve, or a tribal council representing one or more Indian bands which have reserves, or an Indian organization controlled by one or more such bands or tribal councils, if the organization is dedicated exclusively to the social, cultural, educational, or economic development of Indians who for the most part live on reserves, and that the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserve. ...

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