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Technical Interpretation - Internal

15 December 2014 Internal T.I. 2014-0547191I7 F - Chantier particulier

Is a taxpayer considered to be performing duties of a temporary nature for the purpose of subparagraph 6(6)(a)(i)? ...
Technical Interpretation - Internal

15 December 2014 Internal T.I. 2014-0544121I7 F - Chantier particulier

Is a taxpayer considered to be performing duties of a temporary nature for the purpose of subparagraph 6(6)(a)(i)? ...
Technical Interpretation - Internal

14 August 2015 Internal T.I. 2013-0504471I7 - RDSPs and bankruptcy

Because of the agency relationship deemed to exist by paragraph 128(2)(a), there would be no assignment or surrender of the beneficiary’s rights under the RDSP and any payments made from the plan to the trustee in bankruptcy would be considered to have been made to the beneficiary. 2. ...
Technical Interpretation - Internal

9 November 2015 Internal T.I. 2015-0596311I7 - Segway - METC

In our view, a Segway is not sufficiently similar to a standing wheelchair to be considered a wheelchair within the ordinary meaning of the term and the cost will not be an eligible expense under paragraph 118.2(2)(i) of the Act. ...
Technical Interpretation - Internal

16 November 2015 Internal T.I. 2015-0598491I7 - 91(5) & FAPI included per “old” 94(1)(c)(i)(C)

Accordingly, the FAPI-Inclusions trigger permanent adjustments to the ACB of the shares of CFA, which adjustments have to be considered in order to determine any further Canadian tax consequences to NRT in respect of its shares of CFA. ...
Technical Interpretation - Internal

17 March 2016 Internal T.I. 2015-0608931I7 - professional liability insurance premiums

In the case of professional membership dues, the employer is generally considered to be the primary beneficiary of the payment or reimbursement of such dues where membership in that particular professional organization or association is a condition of employment. ...
Technical Interpretation - Internal

30 March 2012 Internal T.I. 2011-0404681I7 - NPO- sports organization

., if the Members actually owned the advertising rights), that income would not be considered to be the income to the Association for the purposes of paragraph 149(1)(l) of the Act. ...
Technical Interpretation - Internal

14 February 2012 Internal T.I. 2011-0422771I7 - Clergy Residence Deduction

" Given that "Ministering" is a very broad concept of serving or attending to the needs of a congregation, diocese or parish, or its individual members, and, accordingly, as stated in paragraph 13 of the Interpretation Bulletin IT-141R(Consolidated) entitled, 'Clergy Residence Deduction', 'if a person who meets the status test is employed within a congregation, he or she is considered to be ministering to a congregation if he or she is fulfilling a pastoral or ministerial role in the manner requested by that congregation.' The XXXXXXXXXX web page states that "XXXXXXXXXX" Based on the above, the duties of a Community Development Pastor appear to be in line with the ideology of the XXXXXXXXXX. ...
Technical Interpretation - Internal

21 July 2016 Internal T.I. 2016-0654751I7 - child care expense and SBJC

The small business job credit would be considered a reimbursement or assistance that may be received by a taxpayer who directly employs a person to care for their child. ...
Technical Interpretation - Internal

31 May 2016 Internal T.I. 2016-0638241I7 - interest deductibility

In situations where some proportion of shares is being replaced with borrowed money, only the capital of those shares, computed on a pro-rata basis, would be considered to be replaced with the borrowed money. ...

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