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8 November 1989 Ministerial Letter 73828 F- Integrated Sawmill & Pulpmill- M & P Deduction Unedited CRA Tags 5202, 125.1(1)   November 8, 1989 Carole Gouin-Toussaint Rulings Directorate Director Frank Gillman Bilingual Services & Resource Industries Division   7-3828 The Special Audits Division has requested that we withdraw one of our previous opinions which states that the "transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & P deduction. ... (b)      all other activities... directly in connection with manufacturing or processing... but does not include any of (d)      ... shipping... of finished goods, (e)      purchasing of raw materials... ... GauvreauChiefResource Industries SectionBilingual Services and Resource Industries Division ...

12 June 1990 Ministerial Letter 59768 F- Canadian Resource Property and Qualified Farm Property Unedited CRA Tags 9, 39, 45(1)(a), 54 capital property, 59(3.2)(c), 66(15) Canadian resource property, 66.2(5), 66.4(5), 110.6 24(1) File No. 5-9768   John Chan   (613) 952-9019 19(1) June 12, 1990 Dear Sirs: Re:  Request for Technical Interpretation- Canadian Resource Property and' Qualified Farm Property under the Income Tax Act (the "Act") We are writing in reply to your letter dated March 12, 1990, wherein you requested a technical interpretation of the meaning of Canadian resource property ("CRP") and qualified farm property under paragraph 66(15)(c) and subsection 110.6(1) of the Act, respectively, in relation to a hypothetical situation herein described. ... Question 3 Can the character of the property change from being a Canadian resource property to something else? ... Further, section 45 may be irrelevant because a CRP is not a capital property.  2.      ...

4 December 1989 Ministerial Letter 73828A F- Integrated Sawmill & Pulpmill Subsection 125.1(1)- M & P Deduction Unedited CRA Tags 125.1(1), 5202   December 4, 1989 E.H. Gauthier Resource Industries Section Director Frank Gillman Special Audits Division 957-9768 Attention:  Merv Scott (Penticton) 7-3828 Forestry Specialist SUBJECT:  Integrated Sawmill & Pulpmill Subsection 125.1(1)- M & P Deduction We are writing in response to your memo dated April 13, 1989, wherein you requested that we reconsider a previous opinion rendered by the Rulings Directorate dated December 1, 1986 as to whether the transportation of woodchips from a sawmill (whether owned by a taxpayer or otherwise) to a pulpmill is a "qualified activity" as defined at paragraph 5202 of the Income Tax Regulations. ... Conclusion 24(1) DirectorBilingual Services & ResourceIndustries DivisionRulings Directorate ...

26 September 1989 Ministerial Letter 58688 F- Supplemental Report Unedited CRA Tags n/a 19(1) File No. 5-8688   Allan B. Nelson   (613) 957-8984 September 26, 1989 Dear Sirs: 24(1)   Supplemental Report Enclosed, as requested in your letter of September 14, 1989, is a copy of the Energy Mines and Resources supplemental report, dated May 18, 1989, which was prepared for Revenue Canada, Taxation concerning 24(1) The release of this report to you is with the concurrence of representatives of both the Edmonton District Taxation Office and the Department of Energy Mines and Resources. Yours truly, ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate c.c.:       Diana Gibson Edmonton district Office      Don SchellDepartment of EnergyMines and Resources ...

19 April 1990 Ministerial Letter 80358 F- Canadian Exploration Expense of a New Mine Unedited CRA Tags 66.1(6)(a)(iii.1)   April 19, 1990 TO Appeals & Referrals Division FROM  Rulings Directorate Appeals Branch Resource Industries   Section Mr. ... The provision formerly read as follows:      "any expense incurred by him after November 16, 1978 for the purpose of bringing a mineral resource in Canada into production and incurred prior to the commencement of production from the resource in reasonable commercial quantities, including..." (emphasis added).      According to the technical notes the change in the wording from mineral resource to new mine results in mine development expenses incurred in bringing a new mine in a mineral resource into production may qualify as Canadian Exploration Expense even though there may have been production from the mineral resource by another mine. ...

12 September 1989 Ministerial Letter 89M09458 F- Rejection of New Mine Status Unedited CRA Tags n/a   September 12, 1989 To: Head Office- Appeals Branch From: Rulings Directorate Appeals and Referrals Division Resource Industries   Section Attention: Mr. ... White   957-8585 Subject: 24(1) We have received a letter, a copy of which is attached hereto, from Helen C. ... Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

29 September 1989 Ministerial Letter 73788 F- Discount on Obligations and Foreign Exchange Losses on Repayment Unedited CRA Tags 9(1), 18(1)(f), 20(1)(f), 39(2), 248(1) principal amount   September 29, 1989 MONTREAL DISTRICT OFFICE HEAD OFFICE Remi St-Louis Bilingual Services & Resource Audit Section Industries Division Section 148 M. ... FACTS 24(1) TAXPAYER'S POSITION 5.     Although paragraph 20(1)(f) of the Act is commonly said to apply to discount on obligations, its actual application may be much broader. 6.     24(1) 7.     24(1) AUDITOR'S POSITION 8.      ... DISCUSSION AND OPINION 17.     Our comments are limited to the questions submitted. 18.      ...

Corporations Unedited CRA Tags 110(1)(d)(iii), 7(1)   September 8, 1989 TO- REVIEW COMMITTEE FROM- RESOURCE   INDUSTRIES SECTION   Allan B. Nelson   957-8984 SUBJECT: Stock Options in U.S. Corporations Subparagraph 110(1)(d)(iii) of the Income Tax Act (the "Act") Background 1.      ... Therefore, the actual amount payable for the shares was only determined when the options were exercised and not at the time the options were granted.       ...

17 December 1990 Ministerial Letter 901578 F- Retirement Counselling Services for Employees Unedited CRA Tags 6(1)(a)(iv)(B) 24(1) 901578   R.D. Weil   (613) 957-2121 19(1) December 17, 1990 Dear Sirs: Re:  Retirement Counselling Services for Employees This is in reply to your letter of July 11, 1990. ... Rather, we view it as being applicable to a seminar or similar type of presentation for employees who are at or near retirement where the purpose of the presentation is to inform and advise them concerning such topics as:-     increasing life expectancy, the impact of inflation on financial resources, post-retirement expectations,-     the level of income that can be expected at retirement from known sources,-     a net worth analysis comparing post-retirement income with expected expenses,-     tax rules related to investments and retirement savings, and-     estate planning techniques and concepts. ...

6 April 1990 Ministerial Letter 59458A F- Classification of Pipeline for CCA Purposes Unedited CRA Tags n/a 19(1) File No. 5-9458   G.R. ... Pursuant to our request that this be done the Department of Energy, Mines and Resources (EMR) has replied a s follows:      "The additional production data provided by  24(1)  in support of their request was available to EMR from other sources at the time of our original analysis, and consequently does not provide grounds for reversing our earlier opinion.  ... Yours truly, Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...