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Technical Interpretation - External

22 February 2021 External T.I. 2018-0784661E5 - Subsection 122.1(1) - Gross REIT revenue tests

In our view, “gross REIT revenue” would exclude amounts that are loan proceeds and equity contributions to the extent that they do not constitute consideration to which the entity expects to be entitled in exchange for goods or services, or as income arising in the course of the entity’s activities. ...
Technical Interpretation - Internal

7 July 2021 Internal T.I. 2021-0890141I7 - Scholarship exemption

This requires consideration of all the circumstances, including the terms and conditions that apply in respect of the award, the duration of the program and the period for which the support is intended to be provided. ...
Technical Interpretation - External

22 December 1992 External T.I. 9216975 F - RPP Regulations Pension Accrual Rate Limits

To determine a defined benefit accrual in a year pursuant to subsection 8302(2) of the Regulations an individual's normalized pension accruing in a year must first be determined taking into consideration the effect of Regulation 8504 on the computation.  ...
Ministerial Letter

15 August 1991 Ministerial Letter 911308 F - Income Allocated to a Retiring Partner

The income calculated by a partnership pursuant to paragraph 96(1)(f) of the Act must take into consideration the partnership's election under paragraph 34(a) of the Act.  ...
Technical Interpretation - Internal

27 September 1991 Internal T.I. 9115647 F - Determination of Residency

The temporary nature of the trip and ties within Canada have become the vital considerations.  ...
Technical Interpretation - External

23 April 1990 External T.I. 32245 F - Definition of Vessel in Canada Shipping Act

We note that the object under consideration in The Gulf Aladdin case was a tanker barge which was pulled by tug from place to place.  ...
Technical Interpretation - External

17 September 1991 External T.I. 115545 F - Qualified Small Business Corporation Share

In particular, we have insufficient information to enable us to determine how the capital gains will arise; however, in general, by virtue of paragraphs 86(1)(b) and (c) no capital gains will arise on a section 86 reorganization of capital where the only consideration received by the taxpayer is shares of another class of the capital stock of the corporation. ...
Ministerial Correspondence

12 September 1990 Ministerial Correspondence 901144 F - Transfer of Depreciable Property into and Out of a Partnership

For all other provisions of the Act, including consideration of the application of subsection 20(1.2) of the ITAR, the actual date of acquisition is applicable. 3.      ...
Ministerial Letter

11 March 1991 Ministerial Letter 902408 F - Residual Interest in a Partnership

The $1 million in the capital account will be the net result of various additions to and reductions from that account, and these adjustments would have been taken into consideration for tax purposes by way of adjusting the ACB of A Co.'s partnership interest.  ...
Ruling

22 May 1990 Ruling 900281 F - Corporate Reorganizations Course Material on Surplus Strips

However, if an election is made pursuant to subsection 85(1), the agreed amount cannot be less than the fair market value of the non-share consideration pursuant to paragraph 85(1)(b).  ...

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