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Principal Issues: Whether alternate and spare parts could be included in Class 34 & 43.1? ... Specific property can only be included in Class 34 if a certificate in respect of the property has been issued by Natural Resources Canada. If, in your opinion, any specific property is eligible for inclusion in Class 34 please contact Richard Fry at Natural Resources Canada (telephone no. 613-996-0890). ...

The common shares of the Corporation are listed on the XXXXXXXXXX under the ticker symbol "XXXXXXXXXX " and are widely held by the public. 4. The business of the Corporation consists solely of the exploration for mineral resources. ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislation Policy Regulatory and Affairs Branch ...

7 July 1990 Income Tax Severed Letter- Capital gains tax treatment — Canada-U.S. ... The term shall in any case include usufruct of real property, rights to explore for or to exploit mineral deposits, sources and other natural resources and rights to amounts computed by reference to the amount or value of production from such resources; ships and aircraft shall not be regarded as real property. ...

13 October 1993 Ruling 9320491- Déductibilité des intérets — Interest Deductibility Unedited CRA Tags 20(1)(c) APFF — CONGRES 1993NOTES AU DOSSIER Question 7 La question de savoir si des actions ordinaires ont été acquises dans le but d'en tirer un revenu est une question de faits et chaque situation doit être examinée en tenant compte des faits particuliers à la situation. ... Par ailleurs, la décision rendue par la Cour canadienne de l'impôt dans l'affaire Mark Resources Inc. le 11 juin 1993 pourrait être utilisée en appui de la position du Ministère à l'effet que les intérêts ne sont pas déductibles. ...

1 March 1988 Income Tax Severed Letter 5-5155- [Sections 25 & 99 of the Income Tax Act] E. Gillman 613)957-8953 March 1, 1988 Dear Sirs, Re: Sections 25 & 99 of the Income Tax Act (the "Act") This is in reply to your letter of November 18, 1987 and following our telephone conversation (Gillman/XXXX) of February 16, 1987 concerning the election of a year-end by an individual who is a member of a partnership after having the partnership elect to rollover all of its assets to a taxable Canadian corporation in virtue of subsection 85(2) of the Act. ... We trust the foregoing will prove helpful. for Director bilingual Services and Resource Industries Division Rulings Directorate ...

3 June 1997 External T.I. 9711835- CONTRACTUAL ARRANGEMENT & SPOUSAL TRUST Unedited CRA Tags 70(6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Murphy A/Section Chief Trusts Section Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

19 February 1988 Income Tax Severed Letter 7-2357- [] DATE February 19, 1988 TO Registration Directorate Registered Pension and Deferred Income Plans Division Dianne Coates Pension Officer FROM Bilingual Services Section R. ... Bilingual Services and Resource Industries Division Rulings Directorate ...

24 January 2003 External T.I. 2002-0180955- Active Solar System & Cogeneration Equip. ... Each of the four micro-turbine units and the eligible service connections can be included in Class 43.1 by virtue of meeting the requirements of paragraphs (a), (b), and (c) of Class 43.1. 2002-018095 XXXXXXXXXX David Shugar (613) 957-2134 January 24, 2003 Dear XXXXXXXXXX: Re: Eligibility for Class 43.1 We are writing in response to your correspondence of March 5, 2002, to Natural Resources Canada (NRCan), wherein you requested their views regarding the eligibility for Class 43.1, of an active solar system and a cogeneration system installed in XXXXXXXXXX (the "Company's") greenhouse at XXXXXXXXXX. ... Yours very truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch ...

18 June 2015 STEP Roundtable Q. 10, 2015-0578541C6- 2015 STEP – Q10- Interest in a Trust as TCP CRA Tags 116(5.01) 116(6.1) 116(5.02) 116(6) 116(5) 248(1) Principal Issues: A testator leaves an estate, more than 50% of which is comprised of real property situated in Canada, (the testator's principal residence). ... Interest in a Trust as Taxable Canadian Property The definition of "taxable Canadian property" (TCP) in subsection 248(1) provides that an interest in a trust (other than a unit of a mutual fund trust or an income interest in a trust resident in Canada) will be TCP if, at any particular time during the 60 month period that ends at that time, more than 50% of the fair market value (FMV) of the interest was derived directly or indirectly from one or any combination of real or immovable property situated in Canada, Canadian resource properties, timber resource properties, and options or interests in such properties. ...

6 July 1998 External T.I. 9804665- TRANSFER TO RESP & DISPOSITION Unedited CRA Tags 54 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Biscaro Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...