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Technical Interpretation - External

8 October 2014 External T.I. 2014-0539231E5 - Indian Employment Income

Guideline 4 also requires that the duties of the employment must be 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

29 September 2015 External T.I. 2015-0601891E5 - Indian Employment Income

Guideline 4 also requires that the duties of the employment must be 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

10 February 2016 External T.I. 2015-0603891E5 - Indian Employment Income and Dividend Income

Furthermore, the courts have also stated that connections that are artificial should not be given weight in determining the location of income for purposes of the exemption. ...
Technical Interpretation - External

23 May 2012 External T.I. 2010-0391511E5 - Split-receipting for fundraising events

We also acknowledge the information provided during our telephone conversations (XXXXXXXXXX/Demeter) in connection with your request. ...
Technical Interpretation - External

27 August 2012 External T.I. 2012-0438001E5 - Taxable Benefits – Employer-Provided Vehicles

Whether a taxable benefit would arise in connection with an employee’s use of an employer-provided vehicle. 2. ...
Technical Interpretation - External

27 November 1998 External T.I. 9822835 - FOREIGN AFFILIATES - FOREIGN ACCRUAL TAX

Reasons: The definitions of foreign accrual tax and underlying foreign tax are very broad. 982283 XXXXXXXXXX Olli Laurikainen (613) 957-2116 Attention: XXXXXXXXXX November 27, 1998 Dear Sirs: Re: United States Limited Liability Companies This is in reply to your letter requesting our views in connection with a hypothetical foreign affiliate structure involving a United States Limited Liability Company (“LLC”). ...
Technical Interpretation - External

13 June 2016 External T.I. 2015-0620371E5 - Clergy Deduction - Aboriginal Spiritual Caregivers

Given the diversity of Canada’s aboriginal peoples, each ASC’s connection to and status in a religious denomination must be considered on a case-by-case basis with consideration to the structure and practices of the particular system of faith of his or her band or community. ...
Technical Interpretation - External

10 March 2011 External T.I. 2010-0390061E5 - Pakistani withholding tax - 126(2)

The term "royalties" is defined as follows in paragraph 4 of Article XII of the Convention: "(a) payments of any kind received as a consideration for the use of, or the right to use, any copyright, patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment and includes payments of any kind in respect of motion picture films and works on film or videotape for use in connection with television; (b) payments received as consideration for technical know how or information concerning industrial, commercial or scientific experience. ...
Technical Interpretation - External

29 March 2011 External T.I. 2011-0395041E5 - Municipal Councillors' Automobile Expenses

For elected municipal officers, subsection 81(3) of the Act provides a further exception to the general rule that allowances paid in connection with an office or employment are taxable. ...
Technical Interpretation - External

29 July 2011 External T.I. 2010-0385511E5 - REIT - Income from Real or Immovable Properties

The Department of Finance Technical Note states: "Rent from real or immovable properties" is currently defined to include rent or similar payments for the use of, or the right to use, real or immovable properties, and payments for services ancillary to the rental of real or immovable properties and customarily supplied or rendered in connection with the rental of real or immovable property. ...

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