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In this regard, "qualified expenditure" is defined in subsection 127(9), in part, as follows: " "qualified expenditure" incurred by a taxpayer in a taxation year means (a) an amount that is an expenditure incurred in the year by the taxpayer in respect of scientific research and experimental development that is an expenditure (i) for first term shared-use-equipment or second term shared-use-equipment... ... XXXXXXXXXX We hope this will be of assistance. for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 2- ...

Olympia floor & Wall Tile v. M.N.R. [[1970] C.T.C. 99] 70 DTC 6085 24(1) 23 We see no competition between equally applicable provisions of the law in the other two cases. ... Director Bilingual Services and Resource Industries Division Rulings Directorate Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

> 90%) of his duties of employment in Country P 6. Individual Y is in Country P to carry out the following activities: (a) To conclude a joint venture contract with a resident of Country P. ... Company A is not engaged in the business of exploring for petroleum, natural gas, minerals or other resources. 8. ...

The GOR is in respect of a Canadian resource property, as defined in paragraph 66(15)(c) of the Act ("CRP"). ... Yours truly, Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

XXXXXXXXXX) This is in reply to your emails dated XXXXXXXXXX in which you requested amendments to the Advance Income Tax Ruling letter issued to the above-referenced taxpayer on XXXXXXXXXX, 2006 (document # 2006-020105 [], the “Ruling”). ... Yours truly, for Division Director Reorganizations and Resources Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

The reasons given are stated as follows: • The taxpayer paid additional amounts to acquire the property prior to drilling because the value of the particular property would be higher since drilling costs were anticipated to be lower than average for the field. • The taxpayer did not incur drilling expenses to the extent of the payments by the other parties. ... The second reason also presumes that the taxpayer has some economic benefit which constitutes a Canadian resource property and which he is relinquishing to the other participants who are making the overpayment in consideration therefor. ... The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Government Assistance Issue The issues are twofold and relate to the position taken in our file # 9809735: 1. whether subsection 127(18) of the Act applies to net government assistance against the SR&ED qualified expenditures only where the government assistance is provided with respect to the construction of a building which will be used primarily for SR&ED, or whether it may also apply where the building will be dedicated primarily to manufacturing but in which substantial SR&ED will be performed, and 2. where the assistance (or a large portion thereof) is received and the building is constructed prior to the commencement of the SR&ED, whether the assistance which can be attributed to the SR&ED is to be netted in its entirety against the SR&ED qualified expenditures in the year such expenditures are first incurred, even if the result is a negative pool balance. ... We hope this will be of assistance. for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch Att. 1 At the time, subsection 87(2.11) had not yet been expanded to include the ITC. 2 By analogy, see Canterra Energy Ltd., 87 DTC 5019, in which the Federal Court of Appeal concluded that the word “minus” in regulation 1207 was used in its mathematical, and hence, technical sense and therefore could lead to a negative amount. ...

11 June 1990 Income Tax Severed Letter AC74568- Investment Tax Credit on Logging Assets Unedited CRA Tags 12(11)(b)(i), Reg. 4600(2)(f) Current Amendments Rulings Directorate Regulations Division Resource Industries Section B. ... This position followed the rationale laid down by the Federal Court of Appeal in Bunge of Canada Ltd. v The Queen [[1984] C.T.C. 284] 84 DTC 6276 where at page 6277 Pratte J stated: "... the equipment required to discharge grain from the appellant's silo was equipment used for `the storing of grain' because the discharge of grain from a silo appears to me to be a necessary and integral part of the storing of the grain... ...

Welcome to the Income Tax Rulings & Interpretations Directorate Bulletin Board. ... DOCN INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE MAILING ADDRESS AND COURIER SERVICE: 25 NICHOLAS STREET 15TH FLOOR, ALBION TOWER OTTAWA, ONTARIO K1A 0L8 TAX SERVICES OFFICES HOTLINE: (613)957-8964 GENERAL ENQUIRY: (613)957-8953 FAX NUMBER: (613) 957-2088 SECURE FAX NUMBER: (613) 957-8946 DOCP INCOME TAX RULINGS & INTERPRETATIONS DIRECTORATE REVISED December 12, 1995 TECHNOLOGY SECTION Roy C. ... Bouffard LEASING & FINANCING SECTION BUSINESS & PROPERTY INCOME AND EXEMPT ORGANIZATIONS SECTION Wayne Douglas, Chief 957-8957 Roberta Albert, A/Chief 957-2100 Fiona Francis 957-8971 Murray Brake 957-2133 Peter Dunn 957-2747 John Brooks 957-2103 Steve Tevlin 957-2746 Bill Guglich 957-2102 Claude Tremblay 957-2744 Carole Chouinard 957-2098 Mary Pat Baldwin 957-2745 Bill Kerr 957-2139 Les Barrows 952-1361 Milled Azzi 957-8972 DEFERRED INCOME PLANS SECTION PERSONAL & GENERAL SECTION Paul Fuoco, Chief 957-2141 Wayne Harding 957-9769 Danielle Zion 957-2140 David Duff 957-8968 Marv Eisner 957-2138 Patricia Spice 952-8984 Annemarie Humenuk 957-2134 Mickey Sarazin 957-3499 Jack Szeszycki 957-2135 Frank Gillman 952-9853 Sandra Short 957-2136 SECTION DE FINANCEMENT, LOCATION ET DES RÉGIMES Jean-Guy Aubé, Chief 957-8963 Ghislain Martineau 957-8962 Maureen-Shea- DesRosiers 957-8961 Adèle St-Amour 952-1764 Louise Roy 957-2092 MANUFACTURING INDUSTRIES, REORGANIZATIONS AND PARTNERSHIPS AND TRUSTS DIVISION FOREIGN DIVISION R. ...

Il semble faire référence à 10 % d'un nombre d'actions et non à 10 % des votes. ... L'allocation du coût en capital réputée réclamée est de 80 000 $. ... Le gain en capital de Gesco calculé en vertu de l'alinéa 40(1)a) de la Loi serait de 100 000 $ (120 000 $ moins le coût de 20 000 $ déterminé en vertu de l'alinéa 85(1)a)). ...