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Gauthier Resource Industries   Director     Section Technical Support Services Peter Lee   (613) 957-8977 Attention: Mervyn Scott         Forestry/Mining Specialist         (West)   7-912003 Logging Tax Deduction- Interest on B.C. ... Act imposes a tax equal to the lesser of: (a)     10% of a taxpayer's income derived from logging operations in B.C., or (b)     150% of the credit that would be allowable under subsection 127(1) of the Act, as if the tax referred to in (a) above was paid. 3.      ... The rationale for our opinion is given in the following paragraphs. 7.      ...

A partnership will be constructing and operating a facility that will involve expenditures on Canadian resource properties which qualify as Canadian oil and gas property expenses  ("COGPE" as defined at paragraph 66.4(5)(a) of the Act), depreciable property and operating expenses. 2.      ... Partner B deals at arm's length with Partner A and Subco. 3.      ... Shortly thereafter the partnership's first fiscal year will end. 6.      ...

23 November 1989 Administrative Letter 58926 F- Calculation of Cumulative Net Investment Loss- Meaning of Investment Expense Unedited CRA Tags 3(a), 3(c), 4(1)(a), 65, 66, 110.6(1) investment expense, 248(1) specified member 19(1) File No. 5-8926   J. Chan   (613) 952-9019 November 23, 1989 Dear Sirs: Re:  Request for Technical Interpretation Paragraphs 110.6(1) "Investment Expense", 3(a) and 3(c) of the Income Tax Act (the "Act") We are writing in reply to your letter dated October 16, 1989, wherein you requested a technical interpretation of the above paragraphs with regards to mining, oil and gas expenses described in sections 65 and 66 of the Act. ... It is our view that resource deductions claimed by an individual would enter into the computation of his investment expense for CNIL purposes where he is a specified member of a partnership in the same fiscal period that the expense is incurred by the partnership. ...

15 June 1993 Administrative Letter 9231896 F- Deductibility of Ontario Mining Tax in Computing Income Unedited CRA Tags 9, 18(1)(a), 18(1)(m), 20(1)(v), 124(4) AUDIT DIRECTORATE RULINGS DIRECTORATE Audit Technical Support Division Resource Industries Section E.H. ... "; (c)     administrative and overhead expenses that are reasonably attributable to the production or sale of the output of the mines; (d)     scientific research expenditures or development research expenditures conducted in Canada and incurred by the operator to the extent that such expenditures are related to the output of the mines; (e)     donations made by the operator for charitable, educational or benevolent purposes which are reasonably related to mining operations in Ontario; (f)     amounts in respect of exploration and development expenditures incurred in Ontario net of Ontario Mineral Exploration Program Act grants and other government assistance but not including resource property purchase costs; (g)     allowed depreciation of mining and processing assets; (h)     expenditures incurred in the transportation of output from the mine to the point of delivery of the output to its purchaser; (i)     pension plan contributions, deductible under the Act, in respect of employees of Ontario mining operations or the processing in Canada of the mine's output; and (j)     the operator's prescribed processing allowance. 8.      ... (c)     The OMT is an income tax. The Representative's Views 12.      ...

4 March 1992 Administrative Letter 9203326 F- T/P Works Outside Canada Less Than 6 Months (7984-1) Unedited CRA Tags 122.3                  March 4, 1992      International Taxation Office     Rulings Directorate      360 Laurier West     K.B. Harding      Room 200C     957-2111      Attention: Doug Wark           920332       Overseas Employment Tax Credit (OETC) Enclosed is a copy of a letter from 24(1) of Calgary. ... The Technical Notes issued by the Department of Finance in 1983, when the the Overseas deduction was replaced by the OETC, stated "(t)he new credit is available to individuals resident in Canada working abroad for six consecutive months or longer for a specified employer in connection with a resource, construction  installation, agricultural or engineering project".  ...

While the Act does not specifically encourage non-resident investment, a mutual fund trust may be said to have the following "advantages" with respect to non-resident investors: (a)      A mutual fund trust is exempt from Part XII.2 of the Act. ... (b)      Provided certain conditions are met, a unit of a mutual fund trust is not taxable Canadian property. ... (c)      Capital gains of the trust can be designated as capital gains of the non-resident beneficiaries (subsection 104(21) of the Act applies only to beneficiaries resident in Canada unless the trust is a mutual fund trust). ...

30 September 1993 Administrative Letter 9322086 F- Transport Employee Expense Unedited CRA Tags 8(1)(g) Head Office- Appeals Branch Business and General Appeals & Referrals Division Division Attention:  Neil Wilson XXXXXXXXXX Transport Employee Expense- Paragraph 8(1)(g) This is in reply to your memorandum of August 4, 1993 in which you requested our views on the deductibility of meal expenses under paragraph 8(1)(g) of the Income Tax Act (the Act) in respect of an individual who is employed by placement agencies and assigned to trucking firms. ... The principal business of a placement agency is not the transportation of passengers and/or goods but rather the supply of human resources to clients in need of temporary manpower assistance. ...

Position TAKEN: A GIFT IN KIND COULD QUALIFY AS GIFT FOR PURPOSES OF SECTIONS 110.1 & 118.1. ... Property is defined in subsection 248(1) of the Income Tax Act (the "Act") as: `"Property" means property of any kind whatever whether real or personal or corporeal or incorporeal and, without restricting the generality of the foregoing, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, (c) a timber resource property, and (d) the work in progress of a business that is a profession;' Paragraph 1 of IT-297R2 states that a "gift" includes a "gift in kind" and paragraph 3 describes the types of property that may and may not be considered gifts in kind. ...

Holloway Assistant Director (613) 957-2104 Client Services Division Attention: Bill Luhta Estates & Trusts Division 4th Floor 962292 Subsection 104(23)(d) of the Act This is in reply to your memorandum dated June 27, 1996, concerning a letter received from XXXXXXXXXX. ... Murphy A/Chief Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

29 August 1989 Administrative Letter 73816- Acquisition du contrôle d'une corporation   Le 29 août 1989 BUREAU DE DISTRICT DE LAVAL BUREAU PRINCIPAL   Section des services Réal Lapointe, Chef bilingues Revue de la vérification Direction des décisions   Charles Thériault   (613) 957-8981      File No. 7-3816 Subject: 24(1) La présente note de service est en réponse a la vôtre du 11 avril 1989 dans laquelle vous demandez notre interprétation sur un problème soulevé par Ginette Prévost de votre Bureau dans une note de service de la même date. ... Le préambule de cet article prévoyait, pour les années d'imposition visées par la présente, ce qui suit:      "125(1).  ... Une compagnie provinciale peut être liquidée volontairement sous l'autorité de la section I de la Loi sur la liquidation des compagnies du Québec ("LLCQ"):      "1.  ...