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26 May 1998 External T.I. 9805745- SALARY / BONUS- REASONABLENESS Unedited CRA Tags 67 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Reasonableness of bonuses paid to shareholders / employees Position: As stated in question 42 of the 1981 Round Table (as clarified in Insights into the 1991 Revenue Canada Round Table Discussion), the Department will not challenge the reasonableness of salaries or bonuses paid to a principal shareholder who is active in the corporation’s business and the corporation has either established 1) a practice of distributing profits to such employee/shareholder in this manner, or 2) a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that in fact are attributable to special know-how or skills of the shareholder. ...

12 June 1998 External T.I. 9713925- AFFILIATED PERSONS, ESTATE, & STOP LOSS Unedited CRA Tags 164(6) 40(3.6) 112(3.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Holloway 971392 Attention: XXXXXXXXXX June 12, 1998 Dear Sirs/ Mesdames: Re: Request for Technical Interpretations Subsections 164(6) and 104(19) of the Income Tax Act (the "Act “) This is in response to your letter of May 21, 1997 requesting a technical interpretation on the operation of subsections 164(6) and 104(19) to a particular fact situation. ...

8 February 1999 External T.I. 9827045- LOANS, MORTGAGES & RRSP Unedited CRA Tags 146(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reg 4900(1)(j) & 4900(4). Reasons: 1-3 See IT-119R4 5 See IT- 320R2 XXXXXXXXXX 5-982704 Fouad Daaboul Attention: XXXXXXXXXX February 8, 1999 Dear Sirs: Re: Loans, Mortgages and RRSP This is in reply to your letter of October 14, 1998, wherein you requested our views in respect of several questions relating to the application of the Income Tax Act (the "Act"). ...

13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3 Unedited CRA Tags 181.2(3)(g) 181.2(4)(e) 181.2(4)(d.1) 181.2(5) 181.2(3)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons FOR POSITION TAKEN: (1)-(3) LEGISLATION, (4) PREVIOUS RULING POSITIONS & 1991 CDN.TAX CONF. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS Unedited CRA Tags REG 4900(1)(e) 146(4) 204(e)(i) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Yours truly, for Director Financial Industries Division Rulings Directorate Policy & Legislation Branch ...

19 July 1996 External T.I. 9623625- PATRONAGE ALLOCATIONS / DIVIDENDS Unedited CRA Tags 135(7) 125(1) 125.1 20(1)(v.1) 1204R Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... " In another speech given at the same tax conference (reproduced at pages 18 and 19 of the aforementioned book) Mr. ...

19 November 1996 External T.I. 9737005- INVESTMENT MANAGEMENT FEES OF RRSP & RRIF Unedited CRA Tags 20(1)(bb) 146(1) 146.3(2)(f) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: RRSP & RRIF investment management fees Position: Confirming and elaborating on our standard position that investment management fees paid by annuitant are considered payment of a premium to RRSP to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

2 December 1996 External T.I. 9621265- ALTERNATE & SPARE PARTS. Unedited CRA Tags CLASS 34 CLASS 43.1 18(1)(A) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Whether alternate and spare parts could be included in Class 34 & 43.1? ...

5 May 1995 External T.I. 9430895- CHILD CARE EXPENSE FOR UI RELATED BUSIN & EMPL INCOME Unedited CRA Tags 63(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: whether UI benefits received in conjuction with the self employment assistance program or the Unemployment Insurance Job Creation Program-section 25 qualify as earned income for purposes of the child care expense limitation Position TAKEN: no Reasons FOR POSITION TAKEN: the amounts received are benefits under the UI Act & are not in connection with the cost of a course or program designed to facilite re-entry into the labour force Youth Programs and Services Human Resources and Development Canada 4th Floor, Place du Portage, Phase IV 140 Promenade du Portage A. ...

29 June 1995 External T.I. 9505455- FLEX PLANS & CONVERSION OF SALARY TO CREDITS Unedited CRA Tags 5 56(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: 1. conversion of salary & other taxable amounts to flex credits 2. cash out of credits to a health spending account Position TAKEN: 1. taxable at the time of conversion under 56(2) and 5(1) 2. cash out provision disqualifies a health spending account as a phsp Reasons FOR POSITION TAKEN: 1. ...