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Technical Interpretation - Internal

14 February 2008 Internal T.I. 2007-0256401I7 F - Vente d'un surplus actuariel

., writing for the Court at page 39. [54] The French version of the statutory provision considered in Nowegijick was not "au titre", it was "quant à". ...
Technical Interpretation - Internal

14 June 2006 Internal T.I. 2006-0179371I7 - Part XIII Withholding Tax

Accordingly, since the copyright in the Script no longer remains with the Vendor, no portion of the payments by the Purchaser would be considered to be a royalty or similar payment in respect of the "production or reproduction" in respect of the copyright in the Motion Picture Rights. ...
Technical Interpretation - Internal

2 May 2005 Internal T.I. 2005-0119971I7 F - CDA - Excessive Election & Late Filed Election

If YCO does not comply with the CRA's request made under subsection 83(3.1) within the ninety-day prescribed period and considering the facts and circumstances surrounding the given situation, the application of subparagraph 152(4)(a)(i) should be considered with respect to Y and the dividend received by him from YCO in 1997. ...
Technical Interpretation - Internal

14 February 2006 Internal T.I. 2004-0096641I7 - Representative of a Member State to the ICAO

We have also examined, on our initiative, the possible application of Article 23 of the VCDR because XXXXXXXXXX could be considered the "head of the mission" according to the VCDR. ...
Technical Interpretation - Internal

3 March 2006 Internal T.I. 2005-0159081I7 - Timing of income inclusion for trust beneficiary

The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. [...]. ...
Technical Interpretation - Internal

31 August 2017 Internal T.I. 2016-0680801I7 - Interpretation- subclause 95(2)(a)(ii)(B)(II) Act

As such, in the Example, to the extent that a portion of the interest paid to FALuxco by MLP is considered to be paid by a member that is not described in subclause 95(2)(a)(ii)(B)(I), that portion should not be recharacterized as income from an active business since it would not be so recharacterized if it had been paid directly by that member. ...
Technical Interpretation - Internal

24 October 2017 Internal T.I. 2017-0719531I7 - Section 22 election and carrying on a business

Purposes of section 22 Because the sale of the business is considered a capital transaction, the sale of accounts receivables of that business at a loss results in a capital loss to the vendor, and a capital asset to a purchaser, which cannot be written down. ...
Technical Interpretation - Internal

24 May 1996 Internal T.I. 9605827 - TAXATION OF RPP RECEIPT IF NO DEDUCTION CLAIMED

In considering the application of subsection 4(4) "double taxation" is frequently considered to occur where a deduction was not taken that would normally offset an income inclusion as occurred in the Langille case. ...
Technical Interpretation - Internal

19 February 1998 Internal T.I. 9720077 F - FRAIS D'ÉTUDE DE FAISABILITÉ

Le juge Noël a fait les commentaires suivants concernant les dépenses réclamées par le contribuable: I do not believe that, as submitted by counsel for the Crown, because the expenses paid by Pigott could, in the event the project was successful, have been paid by First Wentworth upon being billed by Pigott and then could have been considered by First Wentworth as capital expenses and recoverable as capital cost allowances under the Act, should render the expenses non-deductible to Pigott. ...
Technical Interpretation - Internal

28 February 1996 Internal T.I. 9527047 - pre-1972 spousal trust-preferred beneficiary election

Where a trust reports an elected taxable capital gain in a particular taxation year and the right to the capital of a trust has vested in a preferred beneficiary at the end of that year, that beneficiary will be considered to have an interest in the accumulating income of the trust. ...

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