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27 March 1990 Ministerial Letter 90M03238 F- Tax Treatment- Retroactive Pay Increases Unedited CRA Tags n/a   File No. 90M03238   J.D. Jones   957-2104 C.M. PapineauChief, Equal Pay SectionClassification, Human Resources Information Systems and  Pay DivisionTreasury Board of Canada 3rd Floor L'Esplanade LaurierWest Tower Ottawa, OntarioK1A 0R5 March 27, 1990 Dear Mr. ...

19 September 1991 Ministerial Letter 912488 F- Deferral of Payment- Separation Benefits Unedited CRA Tags n/a                Date: September 19, 1991 Senior Management Personnel             W.E. Douglas Human Resources Branch                  957-3497 Room 501 MacDonald Bldg. ...

1 March 1990 Ministerial Letter F3525 F- Flow-through Share Arrangements Unedited CRA Tags 66(15) flow-through share   March 1, 1990 Ms C. Gouin-Toussaint Current Amendments and Director Regulations Division Bilingual Services and Resource Industries Division D.C. ...

19 September 1989 Ministerial Letter 89M09068 F- GAAR Application to Transfer of Mining Business to Set Up a "Successored" Sale to a Subsidiary Unedited CRA Tags n/a   September 19, 1989 Mr. ... Read Resource Industries Acting Assistant Deputy Minister Section Legislative and Intergovernmental John Shaw Affairs Branch Subject: 24(1) Following the decision of the "GAAR" Committee that 24(1) proposal to transfer its mining business to a subsidiary to set up a "successored" sale of its oil and gas business to a subsidiary of 24(1) would be subject to GAAR 24(1) has requested that we examine a revised proposal, whereby the only major resource pool which would be transferred would be its earned depletion base. ... We asked 24(1) for a breakdown of the various resource pools by source (mining or oil and gas) so that we could attempt to determine whether this proposal represented an effort to make a reasonable allocation of the pools.  ...

14 May 1990 Ministerial Letter 59728 F- Meaning of "Franchise, Concession or Licence" FOP CCA Class 14 Unedited CRA Tags 14(5) eligible capital expenditure, 18(1)(b), 20(1)(a), 54 adjusted cost base, 66(15) Canadian resource property, 248(1) property, ITR 1100(1)(c) 24(1) File No. 5-9728   John Chan   (613) 952-9019 19(1) May 14, 1990 Dear Sirs: Re:  Request for Technical Interpretation- Class 14, Schedule II of the Income Tax Regulations (the "Regulations") We are writing in reply to your letter of March 5, 1990, requesting a technical interpretation as to whether a net revenue interest described herein would be a property that is a "franchise, concession or licence" for purposes of Class 14 of Schedule II of the Regulations (hereafter referred to as "Class 14") which provides for      "Property that is a patent, franchise, concession or licence for a limited period in respect of property, except      (a)   a franchise, concession or licence in respect of minerals, petroleum, natural gas, other related hydrocarbons or timber and property relating thereto (except a franchise for distributing gas to consumers or a licence to export gas from Canada or from a province) or in respect of a right to explore for, drill for, take or remove minerals, petroleum, natural gas, other related hydrocarbons or timber;      (b)  a leasehold interest;      (c)  a property included in Class 23; or      (d)  a licence to use computer software. ... Partnership A entered into the following contracts with unrelated third parties: (a)     a gas purchase contract- purchase of gas; (b)     a facilities contract- for the use of facilities to process the gas; (c)     gas gathering and sales lines- for the construction of  lines from the wellhead to the processing facility, and the line from the processing facility to the main pipeline system; and (d)     gas sales agreements- for the sale of gas. 3.      ... CANADIAN RESOURCE PROPERTY Since the aforementioned NRI would entitle Company B to share in non-production sources of income such as the net proceeds on the use of Partnership A's gas processing facilities, fees for Partnership A's construction of certain gas lines and Partnership A's gas processing operations, the NRI would not qualify for treatment as a Canadian resource property pursuant to paragraph 66(15)(c) of the Act. ...

8 June 1992 Ministerial Letter 9215108 F- Change In Control Carryover Of Tax Pools Unedited CRA Tags 111(4), 111(5), 111(5.1)   R. Albert/ga   957-2131 June 1, 1992 Minister/DM's Office     Y.S. 92-3646T Central Records Author Section Chief D.O. (?) ... In some cases when a taxpayer acquires a particular resource property, tax pools related to specifically defined resource expenses may be claimed but only against income derived from the assets which generated the pools.  ...

1 June 1989 Ministerial Letter 58118 F- Joint Exploration Company Unedited CRA Tags 66(15) joint exploration corporation 19(1) File No. 5-8118   G.R. White   (613) 957-8585 June 1st, 1989 Dear Sirs: Re:  Joint Exploration Corporation As requested in your letter of May 11, 1989, we confirm that a principal business corporation will not be disqualified as being a "joint exploration corporation", within the meaning of paragraph 66(15)(g) of the Act solely by virtue of its having had, in the aggregate, more than ten (10) shareholders at any particular time. Yours truly, Chief Resource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate ...

MINISTER/DM'S OFFICE ADM'S OFFICE DM # 9621 CENTRAL RECORDS ADM # 940220 RETURN TO RULINGS, ROOM 303, MET. ... The ineligibility of SR&ED performed offshore for investment tax credits reflects the fact that there is a limit on Canadian resources that can be spent on SR&ED. While the government would like to be more all encompassing in its approach to the funding of SR&ED through the income tax system, I am sure you will appreciate that the limitations on Canada's financial resources make it difficult to do so. ...

DM'S OFFICE (2) # 97-03007M ASSOCIATE DEPUTY MINISTER (1) # 97-02908M ADM'S OFFICE (2) PENDING RETURN TO INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE 15TH FLOOR, ALBION TOWER Signed on July 4, 1997 XXXXXXXXXX Dear XXXXXXXXXX: I am responding to your letter addressed to the Honourable Paul Martin, Minister of Finance, concerning the administration of the Income Tax Act. ... While Revenue Canada dedicates significant resources to providing taxpayers with assistance in interpreting tax legislation, the Department does not pre-approve or sanction specific financial investments. ...

Principal Issues: Basic information on SRED tax credit Position: Basic information provided Reasons: For information only March 8, 2000 Assessment & Collections Branch Income Tax Rulings Directorate Ministerial Correspondence P.G. ... Biscaro, CA Director Resources, Partnerships and Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...