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Hillier A/Director F-3249 Paragraph 48(1)(a) Elections- F-3249 Prescribed Form We have the following comments for your consideration which we discussed via the telephone on September 11: (1)       In the first paragraph you have the taxpayer electing immediately before ceasing to be resident. ...

Our Comments Questions relating tax considerations of a particular taxpayer should be addressed to your local District Taxation Office. ...

As such, the CCA classes of assets in the a terminal should be determined on an individual basis giving consideration to both the specific use that is made of the asset and the degree of connection to or integration with other assets used for an identifiable function in which the asset is used.  ...

The matter was referred to this office for consideration and reply.  We apologize for the delay. 24(1) (c)      24(1) (d)      You have noted that paragraph 3(b) of IT-516 "Tuition Tax Credit" indicates that an educational institution may include a professional organization and that paragraph 26 thereof indicates that examination and application fees are considered to be eligible tuition fees. ...

In the situation described by you, the determination as to whether these arrangements would be RCAs would have to be made after consideration of the relevant facts. ...

Curley, Chief of Verifications and Collections in our Hamilton District for his consideration. ...

However, after careful consideration of the circumstances, it is regretted that a recommendation cannot be made for the remission of taxes paid as a result of the 24(1) The law restricting the purchase of an IAAC became effective after November 12, 1981. ...

An organization's status for purposes of paragraph 149(1)(1) of the Act would be determined on the basis of the facts and details respecting its organization and its actual activities and the GST election should not be a consideration. ...

After careful consideration of the matter and consultation with Current Amendments Division and Legal Branch, we have concluded that an individual may claim a capital gains deduction under section 110.6 in computing taxable income, notwithstanding the fact that there is insufficient net income to absorb the deduction.  ...

With respect to the Decisions Communiqué which you propose to issue, we offer the following comments for your consideration: (i)       Add the word "EXPENSES" after "MOVING" at the end of line 2. ...