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11 September 1996 Income Tax Severed Letter 9525106 - Truck used to transport employees, capital expenditure, scientific research and experimental development

It is our view that, in these circumstances, the truck could qualify as a SR & ED capital expenditure, notwithstanding that the nature of the asset and its direct use do not necessarily impart the typical image of SR & ED activities. ... It is our view that the truck allows the taxpayer to carry on or engage in SR & ED. ... Please do not hesitate to contact the author should you wish to discuss this matter further. for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

6 December 1989 Income Tax Severed Letter ACC8847 F - Canadian Exploration Expenses - Flow-through Shares

It is clear that the reservation of the above-mentioned right, at common law, is a condition subsequent to the making of the contract between the Public Resource Company and the Partnership. ... " (p. 272-273) "...A similar situation can arise with respect to a condition subsequent, as shown by the case of Smallman v. ... A contract with a suspensive condition effectively suspends the performance of the obligations under a contract until the realization of a given condition: "Avant l'arrivée de la condition, l'obligation n'existe que potentiellement mais pas encore réellement. ...

28 February 1984 Income Tax Severed Letter 5-5599 - [Petroleum and Gas Revenue Tax ("PGRT") on Gas Consumed in Processing]

The value of this produced gas is also includable in resource profits under section 1204 of the Income Tax Regulations (the "ITR"). ... The sum of these amounts is (57,500- X) + X = $57,500. Production revenue under this approach is therefore $57,500- 20,000 = $37,500, the same figure as was determined using the first method above. ... Yours truly, Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

10 February 1993 Income Tax Severed Letter 921720C - Farm Support Program

This program is delivered on behalf of Agriculture Canada by Employment & Immigration Canada ("E&IC"). ... This will be accomplished through research, human resource development programs (including awareness and education) the provision of technical and financial assistance for demonstration, on-farm projects and land resource use adjustments. ... RESEARCH BRANCH • One payment of $990,000 is made annually to the National Sciences and Engineering Council (the "NSEC"). ...

2 January 1997 Income Tax Severed Letter ENEWSN - BULLETIN BOARD

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... No amount paid as an allowance & no deeming provision in the Alta Municipal Gov't Act to deem any portion of remuneration to be an allowance. 2. ... Our response in 953237 & 962693 with respect to the $18,000 payments in respect of cash advances and expenses was that in both instances the $18,000 would be income at the time the cash tickets were received. ...

2003 Income Tax Severed Letter 2003-0019881 - Mutual Fund Corporation

XXXXXXXXXX 2003-001988 XXXXXXXXXX, 2003 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Supplementary Advance Income Tax Ruling This is in reply to your letter of XXXXXXXXXX and is supplemental to our advance income tax ruling # 2003-000724 dated XXXXXXXXXX, 2003 (the "Ruling"). ... Yours truly, for Director Reorganizations and Resources Division Income Tax Rulings Directorate Policy and Legislation Branch 4-- 2-- ...

25 March 1986 Income Tax Severed Letter RCT-0408 F

25 March 1986 Income Tax Severed Letter RCT-0408 F Unedited CRA Tags 212(1)(d) Decision Summary Services, Public Utilities & Exempt Corporations Section Reference: Paragraph 212(1)(d) of the Income Tax Act. ... Items (b), (c) and (d) are calculated based on the volume of computer resources needed to process Canco's data. ...

9 July 1979 Income Tax Severed Letter

Dictionary definitions also confirm this- see Funk & Wagnells- that which is obtained as an advantage;- a desired acquisition; Shorter Oxford- increase, of possessions, resources, or advantages, consequent on some action or event;- the action of acquiring; Concise Oxford- increase of possessions;- acquisition of wealth. ...

26 September 1989 Income Tax Severed Letter AC58302 - Barter Arrangement

London & West Riding Investments Ltd. (1967) 1 All E.R. 518 (CA) and cited with approval by then Supreme Court Chief Justice Estey in Stubart Investments Ltd. v. ... Yours truly, Director Bilingual Services and Resource Industries Division Rulings Directorate ...

25 November 1996 Income Tax Severed Letter - BULLETIN BOARD

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... Our response in 953237 & 962693 with respect to the $18,000 payments in respect of cash advances and expenses was that in both instances the $18,000 would be income at the time the cash tickets were received. ... Plant 957-2120 George Keable 957-2046 TECHNICAL REVIEW & REMISSIONS SECTION Bill McCcColm, Chief 957-9226 Martine Filiatrault 952-5803 Sandy Parnanzone 957-9232 Kevin Donnelly 957-2082 Jacques Grisé 957-2059 ...

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