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5 July 2013 Internal T.I. 2013-0491991I7 - Lottery Ticket Retailers

The amount or value of any prize or award received by a distributor or retailer from the provincial lottery corporation is considered to form part of the consideration received for selling lottery tickets and, as such, should be treated as business income of the particular distributor or retailer. ...

2 December 2014 CTF Annual Roundtable Q. 9, 2014-0550441C6 - Q.9 95(6)(b) Post Lehigh

Consideration will be given by the CRA to whether any pre-section 212.3 cases involving foreign affiliate dumping could be challenged under existing anti-avoidance rules, including section 245. ...

6 December 2013 External T.I. 2013-0511591E5 - Political contributions

As noted in the Minister's response of October 28, 2013, your comments about the clarity of the CRA's publications and frontline services have been forwarded to the responsible CRA officials for their review and consideration. ...

15 May 2012 Canadian Petroleum Tax Roundtable, 2012-0446431C6 - 2012 CPTS: Farmout Arrangement

Reasons: In light of the variety of interests that could be granted as consideration for the farmee's undertakings, it is appropriate to consider any particular interest that is to be granted in the context of an individual advance income tax ruling application and according to the historical basis for the administrative treatment. 2012 Canadian Petroleum Tax Conference Question 4-- Farmout Arrangements The CRA's longstanding position on farmout arrangements which do not give rise to proceeds of disposition to the farmor is set forth in IT-125R4, paragraph 14. ...

4 July 2016 Ministerial Correspondence 2016-0647181M4 - Service Animals and the METC

Therefore, I am sending a copy of our correspondence to the Honourable, Bill Morneau, Minister of Finance, for his consideration. ...

13 February 2012 External T.I. 2011-0403561E5 - Unitholders income in year of death

In addition, our comments below do not take into consideration the consequences of any deemed dispositions that may occur as a consequence of death. ...

22 August 2011 Ministerial Correspondence 2011-0415541M4 - medical expenses - attendant care and DTC

Flaherty, Minister of Finance, for his consideration. I trust that the information and referral I have provided are helpful. ...

22 August 2011 Ministerial Correspondence 2011-0416421M4 - Tax paid under the ITA

Flaherty, Minister of Finance, for his consideration. I trust that my comments and the referral are helpful. ...

22 December 2010 External T.I. 2010-0389001E5 - Treatment of Costs of Two Public-Private Projects

Accordingly, we are unable to provide you with any specific comments and we recommend that you should refer this matter to the appropriate TSO for their consideration. ...

6 July 2010 Ministerial Correspondence 2010-0370651M4 - medical devices coagulation meter

Flaherty, Minister of Finance, for his consideration. I trust that the information I have provided and the referral are helpful. ...

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