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You describe the following hypothetical situation: 1.     Partnership X has a fiscal year end ending January 31, 1989. 2.      ... A, a partner, leaves the partnership on July 1, 1989. 3.     The partnership determines Mr. A's share of the profits to July 1, 1989, after the financial results for January 31, 1990 are calculated, in March, 1990, and 4.      ...

(ii)     when a farmer resides and operates a farm outside a prescribed drought region and also maintains a breeding herd in a prescribed drought region where the herd is cared for under a lease arrangement. (iii)     when a farmer resides and operates a farm in one area and during the summer months relocates his breeding herd to a community pasture if either the farmer's own pasture or the community pasture becomes a prescribed drought region. ... (iii)      As outlined above, to be eligible for a deduction pursuant to subsection 80.3(4) of the Act, the breeding herd must be part of a farming business that was carried on at any time during the taxation year in a region that is a prescribed drought region at any time in the year. ...

28 November 1989 Administrative Letter 59046 F- Reply to Letter Unedited CRA Tags n/a 19(1) File No. 5-9046   Maureen Shea-DesRosierss   (613) 957-8953 November 28, 1989 Dear Sir: This is in reply to your letter of August 28, 1989 which was forwarded to us by the Taxpayer Assistance Division. ...

24 October 1989 Administrative Letter 89M10016 F- Ontario Student Assistance Program Unedited CRA Tags n/a   October 24, 1989 Mr. ... Fioravanti   957-2073 Attention: R.J. Menard Ontario Student Assistance Program 19(1) As discussed please find attached the request from the 19(1) concerning the tax returns of the above referred taxpayers. ...

20 December 1989 Administrative Letter 32686 F- Request for Advance Income Tax Ruling Withdrawn Unedited CRA Tags n/a 19(1) 3-2686   D. Watson   (613) 957-2121 December 20, 1989 Dear Sirs: Re:  19(1) In response to your letter of November 30, 1989 we acknowledge the withdrawal of your request for an advance income tax ruling on behalf of the above taxpayer. ...

19 February 1990 Administrative Letter 90M02006 F- 1990 Budget Highlights Unedited CRA Tags n/a   February 19, 1990 Mr. ... Shultis Current Amendments and Director Regulations Division Publications Division   File No. 90M02006 1990 Budget Highlights I wish to let you know that Linda Perron worked all day Saturday helping us put together the 1990 Budget Highlights package.  ...

29 November 1989 Administrative Letter 89M11286 F- Transmission of Documents Unedited CRA Tags n/a   November 29, 1989 Audit Applications Division Technical Interpretations R. ... Parnanzone   957-9232 Subject: 24(1) As recently discussed with Mr. P. ...

19 December 1990 Administrative Letter 903316 F- Reorganization as Part of a Divorce Settlement Unedited CRA Tags 55(3)(a), 248(10) 24(1) 903316   S. Leung   (613) 957-2116 19(1) December 19, 1990 Dear Sirs: Re:  Paragraph 55(3)(a) of the Income Tax Act (the "Act") We are writing further to our letter of March 19, 1990 (file # 5-9293) (the "Letter") which was issued in response to your letter of December 11, 1989 relating to the application of paragraph 55(3)(a) of the Act to a dividend arising in the course of a divorce settlement. ...

4 July 1991 Administrative Letter 910946 F- Scientific Research and Experimental Development- Deductibility of Capital Expenditures Unedited CRA Tags 37(1)(b) Dear Sirs: Re:  Paragraphs 37(1)(b) and 37(7)(c) of the Income Tax Act (the"Act") This is in reply to your letter dated April 4, 1991 in which you requested our view as to whether certain expenditures incurred by a corporate taxpayer for the construction of a processing facility will be considered to be for scientific research and experimental development ("SR & ED") pursuant to paragraph 37(1)(b) of the Act. The question of whether any capital expenditure incurred in the construction of a particular facility is deductible for SR & ED purposes would depend on whether or not such expenditure was incurred for (and was all or substantially all attributable to) the provision of premises facilities or equipment for the prosecution of SR & ED in Canada.  ...

18 January 1990 Administrative Letter 74496 F- Employee Stock Options Exercised After Employee's Death Unedited CRA Tags 70(2), 70(5), 69(1)(c)   January 18, 1990 TO  - Source Deductions Division FROM- Business and General L.P. Mancino, Director Division   A. Humenuk J.C. Wilson 957-2135   File No. 7-4496 SUBJECT:  Employee Stock Options Exercised After the Death of an Employee We are responding to your memorandum of November 7, 1989, concerning 24(1) In her October 27, 1989 letter to you, 24(1) Subsection 70(2) of the Act generally operates to include in income for the final return of a taxpayer, any amount which, if realized, would have been included in the taxpayer's income. ...