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Contributions made by Parentco for years of service performed by the employee to Subco would not be considered to meet the requirements under paragraph 20(1)(r) of the Act and would therefore, not be considered a deductible amount to Parentco. ...

" You also cite in your email, our comments in paragraph 11 of IT-285R2- Capital Cost Allowance General Comments, which reads as follows: "If an old building used by a taxpayer for a long time to earn income is demolished to build a new one, the cost of demolition is not considered to be part of the capital cost of the new building (unless the taxpayer so desires), but may be deducted as an expense in the year. ... However, if as described in paragraph 11 of IT-285R2, the actual facts and circumstances are such that an old building that was used by a taxpayer for a long time to earn income is demolished to build a new one, the cost of demolition is not considered to be part of the capital cost of the new building (unless the taxpayer so desires), but may be deducted as an expense in the year. ...

31 May 2005 Internal T.I. 2004-0106951I7- Shareholder/Manager Remuneration Unedited CRA Tags 15(1) 84(2) 18(1)(a) Principal Issues: Whether the amount paid to each of the shareholders of the corporation should be considered a bonus or a winding up dividend and whether the amounts paid are reasonable in the circumstances. ... Majerus, CA Verification and Enforcement Division (613) 832-3488 2004-010695 Reasonableness of Shareholder/Manager Remuneration This is in response to your email dated December 9, 2004, requesting our views on whether the amounts paid to each of the shareholders of the corporation should be considered a bonus or a winding up dividend and whether the amounts paid are reasonable in the circumstances. ...

Our Comments For a person to be considered a dependant under subsection 118.2(1), pursuant to subsection 118(6) of the Act, the person need only be "dependent upon the individual for support". ... Paragraph 15 of Interpretation Bulletin IT-519R2- Medical Expense and Disability Tax Credits and Attendant Care Expense Deduction, states "a receipt in the name of either spouse is considered acceptable for a medical expense of either, and the amount of that expense may be used by either, as agreed between them. ...

It is apparent from these articles in the Charter that XXXXXXXXXX itself must be the agency brought into relationship with the UN to be considered a "specialized agency". ... In our view, since XXXXXXXXXX is not considered a specialized agency for the purposes of paragraph 8900(a) of the Regulations, XXXXXXXXXX would not be eligible for the deduction under paragraph 110(1)(f) of the Act for 1999 and 2000. ...

14 February 2006 Internal T.I. 2005-0118521I7- Art XV of Canada-US Convention employees of LLC's Unedited CRA Tags Article XV of the Canada-US Tax Convention Principal Issues: Whether a US LLC can be considered to have a PE in Canada for the purposes of paragraph XV(2) of the Canada-US Tax Convention? ... Therefore, our view is that the remuneration received by employees of a US LLC can be considered to be borne by a PE which the employer has in Canada for the purposes of paragraph 2 of Article XV of the Convention. ...

However, because the child has reached the age of majority, we suggest that each actual fact situation involving child maintenance be considered closely to ensure that the requirements of paragraph 60(b) or (c) of the Act are in fact met. ... While it is a question of fact whether a child is in the custody of such an individual, it is generally considered that custody in respect of a child ceases when the child reaches the age of majority (i.e., the age of 18). ...

In Interpretation Bulletin IT-62, entitled Indians, which was cancelled on July 15, 1995, it was stated that dividends on shares of a corporation whose head office, principal business activity and share register were on a reserve would normally be considered to be earned on the reserve. In the Williams case, the Supreme Court of Canada considered the issue as to where income is earned. ...

XXXXXXXXXX Your opinion is that while these costs would be considered capital expenditures for capital cost allowance purposes, they would not qualify as "qualified property" for investment tax credit purposes as new property was not "acquired" in the year. ... Furthermore, subsection 127(11.2) of the Act provides that a qualified property is deemed not to have been acquired by a taxpayer before the property is considered to have become available for use by the taxpayer, determined without reference to paragraphs 13(27)(c) and (28)(d). ...

Based on the understanding that these provincial payments are not considered to be paid under the Employment Insurance Act (the "EI Act"), it is your view that they do not qualify for this exemption. 2.You feel that the above-described "non-repayable grant" would qualify as a bursary for purposes of paragraph 56(1)(n). 3.You feel that, in the case of a $1200 non-repayable grant where only $700 ($1200- $500) is taken into income under paragraph 56(1)(n), subparagraph 118.5(1)(a)(iii.l) would apply to restrict the tuition credit to $700 (assuming that the other requirements of section 118.5 have been met). 4.It is your view that the repayable loan would not be subject to tax. 5.Since the grant is being taxed as a bursary, you feel that the education credit would not be denied but that this seems inequitable, since an individual in receipt of an EI payment relating to the cost of a course or program designed to facilitate the re-entry into the labour force of a claimant under the EI Act (which payment is exempt from tax by virtue of subparagraph 56(1)(a)(iv)) would be denied the credit because of the definition of "qualifying educational program" in subsection 118.6(1). ... That is, the grant will also be considered a bursary for purposes of the definition of "qualifying educational program" in subsection 118.6(1). ...