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Ruling

1999 Ruling 9925273 - PART II.1 TAX

As consideration for the purchase, Acquireco 2 issued common shares to Acquireco 3. ...
Ruling

3 October 2000 Ruling 2000-0036443 - TAXATION OF INDIAN TRUST

You are asking for our consideration of the following five questions: We will address each of your questions below: Question 1 Is the Trust revenue taxable if it is derived from 1) a savings account located at a bank branch situated on the reserve, or 2) investments in certain authorized debt or equity instruments? ...
Technical Interpretation - External

20 October 2000 External T.I. 2000-0041725 - Film Tax Credit

This would entail consideration of the specific facts, including the identities of the parties and any non-arm's length relationships between any of them. ...
Technical Interpretation - Internal

1 November 2000 Internal T.I. 2000-0050867 - CARRYING ON A BUSINESS

Although the facts indicate that the road users will pay an annual fee which is to cover the cost of maintaining the road and that any excess is used to repay the shareholders, will these annual fees also take into consideration such things as depreciation so that the corporation does not report losses for tax purposes each year. ...
Ruling

2000 Ruling 2000-0029483 - Interest paid to non-residents

In consideration for providing the services under the Management Agreement, BCO receives a base fee of $XXXXXXXXXX per annum, and an open-ended incentive fee based on the amount of cash available for distribution by the Fund to its unitholders (which will have been earned by ACO). 7. ...
Ruling

2001 Ruling 2000-0057813 - GIFT TO PRIVATE FOUNDATION XXXXXXXXXX .

The transfer is made without consideration to a registered charity. XXXXXXXXXX 2000-005781 Attention: XXXXXXXXXX XXXXXXXXXX, 2001 Dear Sirs: Re: Advance income tax ruling request: XXXXXXXXXX ("X"), XXXXXXXXXX ("X Co. ...
Ruling

2000 Ruling 2000-0033283 - First Nation Settlement Trust

These rulings are based on the Act as it currently reads and do not take into consideration any proposed amendments thereto. ...
Technical Interpretation - External

16 March 1999 External T.I. 9904765 F - FONDS RÉSERVÉ GARANTIE

Il reste que les modalités de la Police doivent être prises en considération avant de faire une détermination à cet égard. ...
Technical Interpretation - External

14 April 1999 External T.I. 9829145 - HOW ARE IN-TRUST ACCOUNTS TAXED?

We offer the following general comments for your consideration. It is not clear whether the "in trust" accounts are trusts for income tax purposes. ...
Technical Interpretation - Internal

23 April 1999 Internal T.I. 9833137 - STATUS INDIAN, EXEMPT INCOME, SPOUSAL AMOUNT

Sinclair and therefore, taken into consideration in the calculation of Mr. ...

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