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Technical Interpretation - External

1 March 2001 External T.I. 2001-0068715 - Expenses incurred aborted debt offering

Since in the present case a borrowing did not occur, any expenses incurred in connection with the aborted attempt at borrowing are ineligible for a deduction under this provision. ...
Technical Interpretation - External

6 March 2001 External T.I. 2001-0070025 - FOREST RENEWAL BC

., bursaries, by definition, are paid in connection with the pursuit of education, whereas the payment of social assistance has not typically been dependent on the recipient pursuing any particular type of activity. ...
Technical Interpretation - External

14 March 2001 External T.I. 2000-0043015 - VOLUNTEER

The four conditions you have described in your letter are as follows: (1) The person must be employed or otherwise engaged by a government, municipality or public authority ("Employer"); (2) The person must receive an amount for the performance of certain duties as a volunteer; (3) The person must perform specific duties as either an ambulance technician, firefighter or person who assists in the search and rescue of individuals or in other emergency situations; and (4) The person cannot have in the same year been employed by the Employer, otherwise than as a volunteer, in connection with the performance of the duties outlined in (3) above or of similar duties. ...
Technical Interpretation - External

26 March 2001 External T.I. 2001-0064055 - DEDUCT. OF MANAGERS BONUSES&SALARIES

As you know, in our answer to question 42 at the 1981 Canadian Tax Foundation Revenue Canada Roundtable (1981 CTF), we stated that, in general, we will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when (a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or (b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...
Technical Interpretation - External

21 March 2001 External T.I. 2001-0072595 - WINDUP; PARTITION

In particular, should you decide to request an advance income tax ruling, please provide us with the following information and documents: 1. your client's address, 2. your client's tax account number, 3. the identification of the tax services office and taxation center where your client's return is filed, 4. written evidence that you are authorized to act for your client, 5. a deposit of $535.00, 6. an undertaking by you to pay such further fees as may be payable in respect of this ruling application, 7. a statement as to whether any of the issues involved in the ruling request, to the best of the taxpayer's and the taxpayer representative's knowledge: (i) is in an earlier return of the taxpayer or a related person, (ii) is being considered by a tax services office or taxation center 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, and (v) is the subject of a ruling previously issued by the Directorate; 8. a statement of the purpose of each proposed transaction, 9. your interpretation of the application of the provisions of the law that are relevant to each ruling request, 10. a description of the income tax concern that is the cause of the request for each ruling, 11. a complete description of significant transactions that were completed prior to the time of submission of the ruling request or that may be undertaken after the completion of the proposed transactions, 12. a summary of the relevant facts contained in the supporting documentation, 13. with respect to the subsection 245(2) ruling, submissions to establish that the transactions would not result in a misuse of the provisions of the Act or an abuse having regard to the provisions of the Act as a whole, 14. an analysis of authorities which both support the ruling requested and those that do not, with a submission as to why the authorities in support of the ruling requested should prevail, 15. the consent of the taxpayer for release of the ruling, in severed form, to the public (see Appendix A of IC 70-6R4), 16. a statement identifying the information to be deleted from the text of the ruling before it is released, signed and dated by the taxpayer or the taxpayer's authorized representative (see paragraph 16(m) of IC 70-6R4), Further, please note that, per subparagraph 15(d) of IC 70-6R4, we may refuse to rule when the request for a ruling contains alternative courses of action on the part of the taxpayer. ...
Technical Interpretation - External

29 March 1999 External T.I. 9905515 - TRANSFER OF PROPERTY TO A NON-RESIDENT TRUST

XXXXXXXXXX of the XXXXXXXXXX Tax Services Office has advised us that the following information and documentation should be submitted in connection with a disposition of property by a non-resident person to a trust: 1. ...
Technical Interpretation - External

5 May 1999 External T.I. 9908345 - STATUS INDIAN, EXEMPT 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 reserves. ...
Technical Interpretation - External

22 September 1999 External T.I. 9913645 - REPORTING REQUIREMENTS, RCA OR SDA

Retirement Compensation Arrangement A retirement compensation arrangement ("RCA") is defined to include a plan or arrangement under which contributions are made by an employer or former employer of a taxpayer to another person (referred to as a custodian) in connection with benefits that are to be or may be received or enjoyed by any person on, after or in contemplation of any substantial change in the services rendered by the taxpayer, the retirement of the taxpayer or the loss of an office or employment of the taxpayer other than certain excluded arrangements (including SDAs). ...
Technical Interpretation - External

22 January 2019 External T.I. 2016-0645581E5 - Health and welfare trusts (HWTs)

Under the CRA’s revised position on PHSPs, a plan that otherwise meets all of the conditions in paragraph 3 of Interpretation Bulletin IT-339R2, Meaning of private health services plan [1988 and subsequent taxation years], is considered a PHSP as long as all of the expenses covered under the plan are medical or hospital expenses (“medical expenses”) or expenses incurred in connection with and within a reasonable time period following a medical expense, and all or substantially all (generally 90% or more) of the premiums paid under the plan relate to the coverage of medical expenses that are eligible for the medical expense tax credit (“METC”). ...
Technical Interpretation - External

19 March 2019 External T.I. 2018-0748731E5 - Taxation of Settlement Amounts

It is well established that there need only be a small connection between a benefit and the employment, in order to trigger the operation of paragraph 6(1)(a) of the Act. ...

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