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Mancino, Director Division   A. Humenuk   957-2135   File No. 7-3728 Subject:  Taxable Benefits Manual- Automobile Benefits We are responding to your round trip memorandum of March 9, 1989, concerning the technical accuracy of the above noted manual.  ... If the amount is not an expense related to the operation of the automobile, the standby charge would be $270- 200 = $70 and the operational benefit calculated under subsection 6(2.2) would be 1/2 * 270- 0 = $130 for a total taxable benefit of $200. 20)     Page 20, Paragraph 44, "Period":  We think that the word "discrete" should be replaced with the word "finite". 21)     Page 20, Paragraph 45:  As explained in comment 11 above, an allowance does not include a reimbursement. 22)     Page 20, Paragraph 46: A)     Second sentence:  We suggest that the phrase "service men" be replaced with "service personnel". B)     A typographical error was noted in this sentence as the word "sales" has been duplicated. 23)     Page 21, Paragraph 50 & 51: A)     As subparagraphs 6(1)(b)(x) and (xi) apply to subparagraphs 6(1)(b)(v), (vi) and (vii.1) and not to subparagraph 6(1)(b)(vii) of the Act, we think you should amend the references accordingly. ...

X own all the outstanding share capital of Y Co. 3.     Since the date of acquisition, the Property has been rented to Y Co. 4.     Y Co. has continuously used the Property in its business of growing and selling nursery plants which consists of the following activities: i)     cultivation and growing of plants and shrubs for sale at the wholesale and retail level; ii)     purchase of potted plants and shrubs for resale at the wholesale or retail level; and iii)      sale of gardening supplies.       ... C.       Whether the property owned by Mr. and Mrs. X would qualify as a "qualified farm property" is dependent on Y Co. qualifying as a "corporation, a share of the capital stock of which is a share of the capital stock of a family corporation".       ...

21 September 1990 Ministerial Letter 90M11428 F- Revised SR&ED Brochure Unedited CRA Tags n/a   September 21, 1990 Maryanne Taylor Business and General Communications Officer Division Writing and Editorial Services F.B. ... These revisions, highlighted by a red "X" in the left-hand margin, are explained briefly as follows:-         The word "Specialty" has been deleted from the second paragraph of the page preceding the contents.-         The word "of" has been deleted from the phrase "outside of Canada" in the second paragraph on page 3.-         The example on page 6 has been amended.-         The words "at least" have been added to, and the words "or more" have been deleted from, the third paragraph on page 7. ...

3 July 1992 Ministerial Letter 9218428 F- Deductibility Of Mortgage Interest Unedited CRA Tags 18(1)(a), 20(1)(c)   921842   L. Holloway   (957-2131) June 30, 1992 Minister/DM's Office                       YS 92-4865TCentral RecordsAuthor/Section ChiefDistrict OfficeResearch FileTaxpayer's FileReturn to Rulings Directorate, Room 303, Met. signed by Pierre Gravelle on July 3, 1992 19(1) Dear 19(1) I am writing in response to your letter of May 15, 1992, which was forwarded by The Honourable Don Mazankowski, concerning the deductibility of mortgage interest costs incurred in financing your personal residence. ...

16 July 1990 Ministerial Letter 900348 F- Advance Payment of Death Benefits to Terminally Ill Policyholders Unedited CRA Tags 148(9) disposition, 148(9) life insurance policy 19(1) 900348   M.M. Trotier   957-8957   EACC9432 July 16, 1990 19(1) This is in reply to your letter of April 4, 1990 concerning the taxation of the advance payment of death benefits to policyholders suffering from terminal illnesses.  ...

You requested our comments related to the following questions: 1.      ... Given the following facts: a)        During a taxation year, the board of directors passes a resolution that certain cash amounts will be used for the prosecution of SR&ED. b)        The cash is invested on a short term basis until it is actually used. c)        All of the cash is eventually used for SR&ED during the year. d)        The interest income received by the corporation in the taxation year from the investment of the funds exceeds the other revenue of the corporation in the year. e)        All or substantially all of the non-interest income of the corporation for the year is derived from the prosecution of SR&ED.       ... Our Comments Our comments related to the above questions are as follows: 1.      ...

14 May 1990 Ministerial Letter 59728 F- Meaning of "Franchise, Concession or Licence" FOP CCA Class 14 Unedited CRA Tags 14(5) eligible capital expenditure, 18(1)(b), 20(1)(a), 54 adjusted cost base, 66(15) Canadian resource property, 248(1) property, ITR 1100(1)(c) 24(1) File No. 5-9728   John Chan   (613) 952-9019 19(1) May 14, 1990 Dear Sirs: Re:  Request for Technical Interpretation- Class 14, Schedule II of the Income Tax Regulations (the "Regulations") We are writing in reply to your letter of March 5, 1990, requesting a technical interpretation as to whether a net revenue interest described herein would be a property that is a "franchise, concession or licence" for purposes of Class 14 of Schedule II of the Regulations (hereafter referred to as "Class 14") which provides for      "Property that is a patent, franchise, concession or licence for a limited period in respect of property, except      (a)   a franchise, concession or licence in respect of minerals, petroleum, natural gas, other related hydrocarbons or timber and property relating thereto (except a franchise for distributing gas to consumers or a licence to export gas from Canada or from a province) or in respect of a right to explore for, drill for, take or remove minerals, petroleum, natural gas, other related hydrocarbons or timber;      (b)  a leasehold interest;      (c)  a property included in Class 23; or      (d)  a licence to use computer software." FACTS You described the following hypothetical fact situation: 1.      ... Partnership A entered into the following contracts with unrelated third parties: (a)     a gas purchase contract- purchase of gas; (b)     a facilities contract- for the use of facilities to process the gas; (c)     gas gathering and sales lines- for the construction of  lines from the wellhead to the processing facility, and the line from the processing facility to the main pipeline system; and (d)     gas sales agreements- for the sale of gas. 3.      ...

5 December 1989 Ministerial Letter 58488 F- Asset-Backed Commercial Paper Unedited CRA Tags n/a   19(1) 19(1) 5-8488   C. Robb   (613) 957-2744 December 5, 1989 Dear Sirs: We are writing in response to your letter of August 3, 1989 in which you gave requested our opinion on the subject of Asset-Backed Commercial Paper. ...

29 June 1990 Ministerial Letter ACC9478 F- Allowable Outlay and Expenses Unedited CRA Tags 40(1)(a)(i) June 29, 1990 Assessing Programs Section Business & General Non-Resident Taxation Division Division   Rulings Directorate   W.C. ... Lalonde 957-2061   EACC 9478 Subject: Allowable Outlay and Expenses- Subparagraph 40(1)(a)(i) This will reply to your memo of June 8, 1990 in which you request an opinion on the deductibility of an amount paid by a vendor who was required to make a payment to a third party in order to allow him to dispose of a property. 24(1) In our research of this matter we were unable to find a precedent that fits squarely into the circumstances of this case.  ...

3 August 1989 Ministerial Letter 73918 F- Part Year Residents Unedited CRA Tags 118.91, 114(a), 114(b)   August 3, 1989 TO- Non-Resident Taxation Division FROM- Specialty Rulings   Directorate J. ... Laurikainen   957-2125   File No. 7-3918 SUBJECT:  Application of section 118.91 of the Income Tax Act (the "Act") to part year residents of Canada This is in response to your memorandum of May 15, 1989, wherein you enquired about the definition of the term "year" as it is used in section 118.91 of the Act. ...