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Graham September 8, 2017 Dear XXXXXXXXXX: Re: Foreign non-business income tax considered paid by member of a partnership This technical interpretation is in reply to your email of November 27, 2014, regarding the calculation of a foreign tax credit by a member of a partnership. ... B’s non-business income tax in respect of Country X would be considered to include his share thereof paid by AB Partnership. ... B seeks to have something other than a pro-rata amount of the total foreign withholding tax paid by the partnership considered to be a non-business income tax paid by them, the following additional information should, in our view, be provided to support their claim: the name of each partner of the partnership; the Canadian tax identification number, if any, of each partner; the country of residence of each partner; the nature and amount of each partner’s interest in the partnership; the calculation and amount of income allocated to each partner; and the calculation and amount of foreign withholding tax considered to be paid by each partner. ...

Shea-DesRosiers Attention: XXXXXXXXXX December 4, 1995 Dear Sir/Madam, Re: Whether cash gifts and presents to be considered "business income" This is in reply to your letter of September 26, 1995 concerning the above-mentioned subject. You ask whether cash gifts and presents, received by an ordained minister employed with a church, as a guest speaker at various religious organizations, for providing eulogies at funerals and officiating at marriages and other religious ceremonies without any fee having been requested, can be considered business income. ... You state in the first paragraph of your letter that the ordained minister is "employed with a church" and in the last paragraph of your letter you enquire as to whether the gifts and presents should be considered "business income". ...

To determine if it is considered a municipality, a First Nation should contact the Agency's local tax services office. ... For a First Nation that is a municipality, the geographical boundary is considered to be the boundary of its reserve. ... However, if Corporation C only owns 95% of Corporation D, Corporation D is not considered exempt. ...

Is a paper return, filed by a tax preparer, still considered a validly-filed return for the purposes of the taxpayer? ... Where electronic filing is required by either subsection 150.1(2.1) or (2.3), is a paper return still considered a validly-filed return for the purposes of subsection 150(1) and the late-filing penalty in subsection 162(1)? ...

All subsequent year non-capital losses that have previously been deducted under paragraph 111(1)(a) should be considered. ... Where this occurs under either instalment method, that particular method will not be considered. ... Should previously applied non-capital losses from subsequent years be considered in recalculating CAD Taxes Payable resulting from a subsequent deduction for an additional non-capital loss? ...

In view of the above, it is our opinion that where it can beestablished that more than 5O% of the use of a farm residence, owned by a farm partnership, is used as accommodation for persons (or their dependants) who are actively employed in the farming business, such residence would be considered to be property used in the business of farming for purposes of the definition of "interest in a family farm partnership" in subsection 110.6(1). ...

Our Comments XXX on subsection 247(2) which has considered the meaning of the reference to "... one of the main reasons... ...

Tax consequences (a) The amount of financial assistance relating to the destruction or total loss of such buildings will be considered the proceeds of disposition for the land and the building. ... Financial Assistance for damage (not considered a total loss) incurred by the owner of a residence. certain rental buildings and business properties Assistance- The owner could receive 100% of the value of the damage to the building, up to $100,000, plus 75% of the amount exceeding $100,000, but not more than 100% of the standard municipal assessment of the building alone, if the owner has suffered damage to the property mentioned in the preceding section, but not a total loss.- For essential business property or property required for the continuation of business operations, the Quebec government order 973-96 states that the damage to the land (except for cultivated agricultural land) and its landscaping, or to a woodlot, sugarbush or tree plantation are not eligible for financial assistance. ...

Are fax machines, printers, security systems or other machinery considered? ...

The issues considered in the case The issues which the Tax Court had to consider included the following: 1. ...