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Technical Interpretation - External
23 April 2007 External T.I. 2006-0218131E5 - medical reports for the purpose of litigation
If such entitlement exists, pursuant to paragraph 118.2(3) of the Income Tax Act, the amount will not be considered a medical expense unless the amount of the reimbursement is required to be included in computing income and is not deductible in computing taxable income. ...
Technical Interpretation - External
9 May 2007 External T.I. 2006-0205741E5 - partition of property
In applying subsection 248(21) to the second subdivision and partition, it is your view that the Remaining Property should be considered "a property" and the reference to "parcel of land" in paragraph 248(21)(c) of the Act should refer to the 120 lots in phase two and the Second Remaining Parcel. ...
Ministerial Correspondence
16 April 2007 Ministerial Correspondence 2007-0227411M4 - RESP - Meaning of "Enrolled"
Any proposal to change tax policy or legislation would have to be considered by the Minister of Finance and approved by Parliament. ...
Technical Interpretation - External
25 May 2007 External T.I. 2007-0231211E5 - support amount
Otherwise, amounts in an order or agreement are considered to be support for your children. ...
Technical Interpretation - External
31 May 2007 External T.I. 2007-0223081E5 - Commercialization Investment Funds Program
We have also assumed that a general partnership structure, rather than a limited partnership structure, is contemplated, such that the "at-risk rules" in subsection 96(2.1) to (2.7) of the Income Tax Act (the "Act") need not be considered. ...
Technical Interpretation - External
11 June 2007 External T.I. 2006-0185291E5 - Capital Dividend Account
You have asked whether, in reviewing the above election, the Canada Revenue Agency (the "Agency") would be able, essentially, to deny an addition to the corporation's CDA, in respect of an amount originally characterized as a capital gain in a previous taxation year that is now statute barred, for amounts that may be considered to be on income account. ...
Ministerial Correspondence
12 June 2007 Ministerial Correspondence 2007-0234591M4 - Guidelines - Status Indians
The Supreme Court of Canada has directed that "connecting factors" must be considered when making such a determination. ...
Technical Interpretation - External
3 July 2007 External T.I. 2007-0228581E5 - Employer-paid tuition as benefit
" We also draw your attention to the comments on "Specific Employer-Related Training", which may be applicable in your situation: "Courses which are taken for maintenance or upgrading of employer-related skills, when it is reasonable to assume that the employee will resume his or her employment for a reasonable period of time after completion of the courses, will generally be considered to primarily benefit the employer and therefore be non-taxable. ...
Technical Interpretation - External
14 August 2007 External T.I. 2007-0235861E5 - Medical Expense Tax Credit
Reasons: Payments for Rolf therapy would not qualify as eligible medical expenses unless amounts were paid for "medical services" performed by a medical practitioner authorized to practice as such according to the laws of the jurisdiction in which the service was rendered. 2007-023586 XXXXXXXXXX Ian Scowcroft (613) 948-2233 August 14, 2007 Dear XXXXXXXXXX, Re: Medical Expense Tax Credit This is in response to your letter of May 10, 2007, inquiring about whether Rolf therapy would be considered as an eligible medical expense, and whether a Rolf therapist would be classified as an 'authorized therapist'. ...
Technical Interpretation - Internal
7 August 2007 Internal T.I. 2007-0240691I7 - Music CD production-CCA class
., a tape or disk) used in the music industry for the making of records, tapes and compact disks is considered to include the costs related to the production of the master recording medium. ...