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Technical Interpretation - Internal

29 January 2002 Internal T.I. 2001-0107777 - LICENSE TO USE TECHNOLOGY

Because the patents had not yet been granted, the Commercialization rights could not be considered "a right to use patented information" within Class 44. ...
Technical Interpretation - Internal

11 December 2001 Internal T.I. 2001-0114067 - NEW POLICY ON GIFTS & AWARDS

The new policy does not apply to gifts and awards given by closely held corporations to their shareholders or their relatives, since these gifts and awards are normally considered to be received by the individuals in their capacity as shareholders. ...
Technical Interpretation - Internal

25 February 2002 Internal T.I. 2002-0118117 - PART 1.3 - ADVANCES & HOLDBACKS

The holdbacks payable are clearly not reserves or other surpluses for accounting purposes but it is not clear as to whether they would be considered provisions. ...
Technical Interpretation - Internal

23 May 2002 Internal T.I. 2002-0132797 - partnership salary

Accordingly, where a distribution made to a partner exceeds the partner's share of the allocable partnership income, the excess would be considered to be a withdrawal from capital. ...
Technical Interpretation - Internal

12 June 2002 Internal T.I. 2002-0127357 - Corporate Late-Filing Penalty

In your situation, a corporation's due date for filing its income tax return falls on a Sunday, and so the return would be considered to have been filed on time if it had been received on the following day, i.e., Monday. ...
Technical Interpretation - Internal

19 July 2002 Internal T.I. 2002-0129737 - EMPLOYEE PROFIT SHARING PLAN - SR & ED

We have not considered whether this type of situation is one to which subsection 245(2) might apply. ...
Technical Interpretation - Internal

29 July 2002 Internal T.I. 2002-0141080 - settlement-retiring allowance

Generally, amounts received in respect of a loss of office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal, are considered retiring allowances and are taxed under subparagraph 56(1)(a)(ii) of the Income Tax Act (the "Act"). ...
Technical Interpretation - Internal

31 July 2002 Internal T.I. 2002-0143137 - EXPENSES & BENEFITS YACHTS

Specifically, paragraph 11 of IT-432R2 indicates that where a corporate property is made available for the personal use of a shareholder, a benefit under subsection 15(1) of the Act is generally considered to have been conferred on the shareholder. ...
Technical Interpretation - Internal

8 August 2002 Internal T.I. 2002-0149967 - DAMAGES RA HUMAN RIGHTS VIOLATION

This document may describe certain human right violations that would have been considered by the Employer in establishing the Settlement Amount. ...
Technical Interpretation - Internal

6 September 2002 Internal T.I. 2002-0153867 - Status Indian Telework

While participating in the telework arrangement outlined in the Telework Agreement and until such a time as the Telework Agreement is terminated, the employment duties performed by the above-noted taxpayer at her on-reserve work location are considered employment duties performed on a reserve for purposes of the Guidelines. ...

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