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Technical Interpretation - External
7 June 2005 External T.I. 2005-0126661E5 - Medical exp. tax credit-learning disability
The CRA recognizes that an individual suffering from a behavioural problem arising out of a mental or physical impairment or suffering from a learning disability who attends a school that specializes in the care and training of persons who have the same type of problem or disability is considered to qualify under paragraph 118.2(2)(e) of the Act. ...
Technical Interpretation - External
5 December 2005 External T.I. 2005-0155331E5 - XXXXXXXXXX 2006 Meeting - Q & A's
Does the answer to 1) change depending on the ownership of the limited partnership units in the Fund (for example, if any limited partners would be considered a specified non-resident shareholder if they made loans directly to Amalco)? ...
Technical Interpretation - External
23 December 2005 External T.I. 2005-0163751E5 - test wind turbines - CRCE
In particular, we are not providing any confirmation as to the extent to which any particular equipment, such as the proposed electrical substation for Phase 2 of the Project, may be considered to be a "Canadian renewable and conservation expense" ("CRCE"), as defined in subsection 66.1(6) of the Income Tax Act (the "Act"). ...
Technical Interpretation - External
6 February 2018 External T.I. 2017-0732151E5 - Timber Resource Property
In particular, you have asked whether the proceeds of disposition would be considered as proceeds of disposition of an eligible capital property. ...
Technical Interpretation - External
9 April 2018 External T.I. 2017-0735431E5 - CEE for Discovery Wells
Typically, there are industry standards as well as provincial regulatory requirements for an oil or gas well to be considered abandoned. ...
Technical Interpretation - External
15 December 1998 External T.I. E9821495 - FOREIGN AFFILIATES - FOREIGN TAX / LLCS
We also note that the tax paid by Canco would be considered to be paid in respect of income from a share of the capital stock of a foreign affiliate and is therefore not eligible for deduction from tax under subsection 126(1) of the Act or for a deduction in computing income under subsection 20(12) of the Act. ...
Technical Interpretation - External
11 February 1997 External T.I. 9527465 - Common Trust Funds - Plan of Operation
Therefore, a plan of operation is not considered to be a document similar to a prospectus or registration statement for the purposes of paragraph 4803(2)(a) of the Regulations and the units of a common trust fund which files such a document would not be "qualified for distribution to the public" under paragraph 4801(a) of the Regulations. 5-952746 XXXXXXXXXX G.W. ...
Technical Interpretation - External
12 August 1997 External T.I. 9715715 - SALARY DEFERRAL ARRANGEMENT REG. 6801(A)
Pursuant to subparagraph 6801(a)(iv) of the Regulations, the Plan must provide that any interest or additional amounts (capital gains) that may reasonably be considered to have been earned for the benefit of the employee in a year must be paid in that year to the employee. ...
Technical Interpretation - External
9 February 1998 External T.I. 9725475 - foreign affiliates - active business income
Reasons: After the merger, the borrowed funds are considered to be used for the purpose of earning income from the shares of foreign affiliate which survives the merger. 972547 XXXXXXXXXX Olli Laurikainen (613) 957-2116 Attention: XXXXXXXXXX February 9, 1998 Dear Sirs: Re: Foreign Affiliates- Paragraph 95(2)(a)(ii)(D) This is in reply to your letter dated September 22, 1997. ...
Technical Interpretation - External
6 April 1998 External T.I. 9802375 - CHILD SUPPORT
On the basis that your daughter may no longer be considered a “child of the marriage” as a result of the above circumstances and that your spouse is not supporting your son, you are considering to apply to the Ontario Court (General Division) for an order under which you would no longer be required to pay support for these two children. ...