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Technical Interpretation - External

5 February 2010 External T.I. 2009-0352151E5 - Non-arm's Length Transactions with Non-residents

Yes Reasons: USCO is considered a "reporting person" who has a "reportable transaction" per the definitions of subsection 233.1(1). ...
Ministerial Correspondence

9 February 2010 Ministerial Correspondence 2009-0348271M4 - Eligible expenditures- home renovation tax credit

Generally, land of 1/2 hectare (1.24 acres), including land upon which the individual's housing unit stands and any portion of the adjoining land, will be considered part of the individual's eligible dwelling if the individual owns the land. ...
Technical Interpretation - External

17 February 2010 External T.I. 2009-0351581E5 - PHSP

You have asked whether the coverage for expenses that are of the types described in subsection 118.2(2) of the Act would be considered to be non-taxable benefits to the employees. ...
Technical Interpretation - External

24 February 2010 External T.I. 2009-0343541E5 - Health and Welfare Trusts

For example, an employer's contribution to a trust is generally non-deductible because it is considered to be a contribution of capital. ...
Technical Interpretation - External

18 February 2010 External T.I. 2009-0348491E5 - Capital expenditure

This paragraph provides a discussion on whether an expenditure is considered to be maintenance because it restores a capital property to its original condition (likely a current expense) or a betterment because it materially improves a capital property beyond its original condition (likely a capital expenditure). ...
Technical Interpretation - External

13 July 2017 External T.I. 2017-0702001E5 - Principal residence, land

In the situation you described, assuming the land on which your house was situated did not exceed 1/2 hectare, such land would normally be considered to form part of the property that could be designated as your principal residence provided the other conditions for claiming the principal residence exemption were met. ...
Conference

13 June 2017 STEP Roundtable Q. 11, 2017-0693331C6 - Substituted property of estate

In the context of the conversion of shares from one class to another, the determination of whether subsection 70(6) could apply is dependent on whether the shares held by the deceased taxpayer at his or her death were considered to have been transferred or distributed to and vested indefeasibly in the spousal trust prior to the share conversion. ...
Technical Interpretation - External

3 April 2008 External T.I. 2007-0248031E5 - Part XIII on repayment of debt

In the circumstances, it appears that the payment is a completed transaction, and as such, is subject to audit and assessment by the Canada Revenue Agency as considered warranted by the Compliance Programs Branch. ...
Technical Interpretation - Internal

12 March 2008 Internal T.I. 2007-0261541I7 - Deemed residency

Your position is that the moment which is "immediately prior to appointment or employment" refers to the moment of the communication and acceptance of an offer of employment by the individual or that can be considered such a moment. ...
Technical Interpretation - External

2 May 2008 External T.I. 2008-0265681E5 - Tax Shelters and ss. 16.1(1) election

However, we have considered your enquiry and provide the following comments, which are of a general nature only. ...

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