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Martineau   (613) 957-8953 Le 16 février 1990 Monsieur, La présente est en réponse à votre lettre du 29 septembre 1989 dans laquelle vous nous référez à la situation hypothétique suivante: 1.      ... Monsieur A détient toutes les actions émises de Parent Inc. 2.     Filiale Inc., une filiale à propriété exclusive de Parent Inc., détient aussi des valeurs mobilières qu'elle considère comme des biens en immobilisation au sens de l'alinéa 54b) de la Loi de l'impôt sur le revenu (la "Loi"). 3.      ... Ces valeurs mobilières seront des biens en inventaire pour Parent Inc. 4.      ...

In this regard, XXXXXXXXXX has requested any assistance you can provide with respect to the interpretation of the following phrases contained in subparagraphs 204.4(2)(a)(iii) and (iv) and subsections 204.6(2) and (3) of the Act: 1.     "the fair market value at the time of acquisition"; 2.     "the aggregate of all amounts each of which is an amount owing by it on account of its acquisition of real property"; and 3.      ... We agree with XXXXXXXXXX that "an amount owing on account of the acquisition of real property" would include (a)     principal and accrued interest owing in respect of any mortgage assumed on the acquisition of a real property, (b)     principal and accrued interest owing in respect of any mortgage negotiated to finance the acquisition of a real property, (c)     principal and accrued interest owing in respect of any mortgage negotiated to finance construction of a building, and (d)     principal and accrued interest owing in respect of any mortgage negotiated to refinance the debt referred to in any of (a) to (c) above and (e) below. ...

A, buys an interest in AB Partnership, a newly formed limited partnership, for $100. 2.      ... B, is the only general partner. 3.     Mr. A was approached personally by Mr. ... B's personal recommendation. 4.     Pursuant to the partnership agreement, Mr. ...

27 November 1989 Administrative Letter 58896 F- Deferred Salary Leave Plan- Calculation of CPP and UI Premiums Unedited CRA Tags n/a 19(1) File No. 5-8896   W.C. Harding   (613) 957-3499 November 27, 1989 Dear Sirs: This is in reply to your letter of September 13, 1989 addressed to our Source Deductions Division and referred to us for reply. ... The Department, in consultation with the Justice Department and the Departments of Finance, Employment and Immigration, and Health and Welfare, has determined that: a)     U.I. premiums are to be based on the employee's gross salary before deferrals during the period of deferral and no premiums are to be withheld from the deferred amounts when paid to the employee during the leave period. b)     C.P.P. premiums are to be based on the salary the employee actually receives during both the deferral period and the leave period.  ...

. #90026006 Return signed copy to: Technical Review Section Technical Publications Division Room 1016, Cumberland Place   July 25, 1990   EACC9384 19(1) 19(1) I am writing in response to representations made on January 19, 1990 by your member of Parliament, the Honourable Douglas G. ... ReadActing Assistant Deputy MinisterLegislative and IntergovernmentalAffairs Branch c.c.      ... Lewis, P.C, F.C.A., Q.C., M.P., Minister of Transport House of Commons Room 356, Confederation Building Ottawa, Ontario c.c.      ...

11 July 1989 Administrative Letter 57856 F- Transferability of Annuity Payments to RRSP Unedited CRA Tags 17(8), 60(j) 19(1) File No. 5-7856   W.C. Harding   (613) 957-3499 July 11, 1989 19(1) This is in reply to your letter of April 4, 1989 and in confirmation of our telephone conversation of June 22, 1989 19(1) Harding) concerning the transferability of your 24(1). ... In particular it is proposed that: a.     lump sum transfers, such as upon commutation of a pension annuity, may only be transferred on a direct plan basis after January 1, 1989 and b.      ...

20 March 1990 Administrative Letter 74466 F- Assignment of Herring Licences Unedited CRA Tags 14(5) eligible capital expenditure   March 20, 1990 VICTORIA DISTRICT OFFICE HEAD OFFICE Bruce Donaldson Financial Industries Division Chief of Audit C. Robb   (613)957-2744 Attention: Brian Rowden Section 148-1-1 File No. 7-4466 Subject: Assignment of Herring Licenses We are writing in response to your memorandum of October 23, 1989 in which you asked for our comments concerning the assignment of herring licenses. The situation described in your memorandum can be summarized as follows:      A person ("A") owns an unlimited life herring fishing licence, which under the Fisheries Act (Canada) is not transferable. ...

6 July 1989 Administrative Letter 74076 F- Pipeline Right of Way and Easement Costs Unedited CRA Tags n/a   July 6, 1989 Mississauga District Office Head Office Appeals Division Resource Industries W 5est Section   Allan B. Nelson Ted Clarke (613) 957-8984   File No. 7-4076 Subject:  24(1) Pipeline Right of Way and Easement Costs Enclosed, as requested in your round trip memorandum dated June 26, 1989, is a copy of our July 4, 1986, reply to Audit's memo dated February 24, 1986, concerning pipeline right of way and easement costs. ...

22 February 1990 Administrative Letter F3546 F- Shareholder's Benefit Unedited CRA Tags 15(1)   February 22, 1990 Mr. ... McColm   957-2068   File No. F-3546 Subsection 15(1) The Department of Finance has written, a copy of their letter is attached, asking for an interpretation of subsection 15(1) of the Income Tax Act in a particular fact situation they describe. ...

26 October 1993 Administrative Letter 9322656 F- Deferred Property Tax Unedited CRA Tags 12(1)(x), 18(1)(a), 18(1)(e) Client Assistance Directorate Business and General Other Returns & Guides Division Attention:  G. ... "program" means the Farm Land Identification Program 5(1) The following real property shall be eligible for registration under the program: (a)     land used for the production of agricultural products; (b)     land capable of being used for agricultural production in the year of application; (c)     land which is being cultivated from time to time or managed for the production of food for humans or livestock; and (d)     land referred to in paragraph (a), (b), or (c) and farm outbuildings. 7 Notwithstanding section 5, no real property shall be registered under the program if it cannot be classified as real property capable of use for agricultural purposes on a commercial basis at the time of application for registration under the program. Our Comments: Briefly, paragraph 12(1)(x) of the Income Tax Act (the "Act") provides, inter alia, that there shall be included in computing the income of a taxpayer for a taxation year as income from a business or property any amount received by the taxpayer in the year, in the course of earning income from a business or property, from a government where the amount (received) can reasonably be regarded as: 1)     an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or 2)     as a reimbursement, contribution, allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of the cost of property or in respect of an outlay or expense. ...