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Technical Interpretation - External
9 August 2011 External T.I. 2011-0392741E5 - Meaning of Farming - Marijuana Growing
In determining whether a taxpayer is an employee or self-employed person, consideration is generally given to the following four criteria: (1) the extent to which the worker is subject to the control of the payor, (2) whether the worker provided his or her own tools, (3) whether the worker has a chance of profit or risk of loss, (4) whether or not the worker is employed as part of the business and performing services integral to the business. ...
Technical Interpretation - External
19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares
For example, this could be the case where shares are issued by a corporation for consideration that is less than the fair market value of the said shares. ...
Technical Interpretation - External
20 October 2015 External T.I. 2015-0574241E5 - Payments to First Nation (XXXXXXXXXX) Elders
In common law jurisdictions, the courts have said that a bona fide gift exists when there is a voluntary transfer of property without consideration. ...
Technical Interpretation - External
27 January 2017 External T.I. 2013-0482351E5 - Clause 95(2)(a)(ii)(D)
Notwithstanding our comment above, in a situation where the surplus balances are increased or decreased inappropriately, consideration will also be given to the application of specific anti-avoidance rules as well as the General Anti-Avoidance Rule in section 245 of the Act. ...
Technical Interpretation - External
16 May 2017 External T.I. 2016-0670661E5 - Capital Cost of De-icing Equipment
In broad terms, this requires a consideration of the intent of the annexation to the building. ...
Technical Interpretation - External
13 August 2009 External T.I. 2009-0318031E5 - Indian Employment Income - Pilot
In calculating the time spent performing duties on a reserve, the same considerations apply with respect to proration as with respect to Guideline 3. ...
Technical Interpretation - External
19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie
1-2 C) Est-ce que la filiale doit prendre en considération le CBR de Mèreco dans le calcul de son CDC et vice versa? ...
Technical Interpretation - External
22 May 2008 External T.I. 2008-0264561E5 - Subsection 89(7) Calculation
In general terms, the amounts described in paragraphs (a) and (b) of the value for "A" will reflect 63% of the total of the corporation's "full rate taxable income" for each taxation year of the corporation ending after 2000 and before 2006, with certain modifications depending on the taxation year in question, determined before taking into consideration the specified future income tax consequences for the year. ...
Technical Interpretation - External
25 September 2008 External T.I. 2008-0275351E5 - Tax implications of solar panel roof
Reasons: 1) The amounts received are in consideration for goods provided pursuant to the terms of a contractual arrangement between the taxpayer and the Ontario Power Authority and / or local utility company. 2) Consistent with the comments provided in IT-120R6. 2008-027535 XXXXXXXXXX Bob Naufal (613) 957-2097 September 25, 2008 Dear XXXXXXXXXX: Re: Installation of a Solar Panel Roof We are writing in response to your letter dated April 14, 2008 to the Sudbury Tax Services Office and forwarded to our Directorate on April 17, 2008 for response. ...
Technical Interpretation - External
20 November 2008 External T.I. 2008-0296181E5 - renewable Energy Projects - Tidal Energy
20 November 2008 External T.I. 2008-0296181E5- renewable Energy Projects- Tidal Energy Unedited CRA Tags Ewg 1100; reg 1219(1); 66(15) Principal Issues: Discussion of tax incentives available for renewable energy projects-- tidal wave energyprojects- tidal wave energy Position: general discussion XXXXXXXXXX 2008-029618 Lena Holloway November 20, 2008 Dear XXXXXXXXXX Re: Renewable Energy Projects- Tidal Energy We are writing in response to your e-mail correspondence of October 7, 2008, requesting information on any special income tax considerations concerning tidal energy projects. ...