Mr. Bert Titcomb
Energy Efficiency Division
Efficiency & Alternative Energy 920346
Technology Branch W.P. Giglich
Energy Mines and Resources Canada (613) 957-2102
580 Booth Street
Ottawa, Ontario
K1A 0E4
March 12, 1992
Dear Sirs:
Re: Class 34
This is in response to your fax letters of January 30 and February 6, 1992 wherein you request our views concerning your draft letters respecting eligibility of property for certification under class 34. Our comments regarding your draft letters follow:
* The second sentence of paragraph 3 of your 24(1) letters states "Revenue Canada is responsible for the administration of the Income Tax Act and Regulations, including all non-technical criteria for inclusion of property in Class 34". We assume the non- technical criteria you are referring to is non-mechanical and non-scientific criteria. However the word technical has other meanings including special and practical knowledge of a subject, specialization and legal interpretation. In the Income Tax literature the word technical is often used in a non-mechanical and non- scientific context (eg.: technical interpretations of the Act, technical information respecting the provisions of the Income Tax Act). Please refer to our comments in the last paragraph on page one of our letter of October 7, 1991, (copy attached).
We trust our comments will be of assistance to you.
Yours truly, E. Wheeler for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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