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17 June 1992 Administrative Letter 9201386 F- Replacement & Qualified Farm Property- Foreign Unedited CRA Tags 44(5), 110.6(1) qualified farm property (a)   June 17, 1992 Audit Technical                                   Manufacturing Industries, Support Division                                     Partnerships and Trusts Division Attention:  Phil Jolie                              G. ... However, in 1988 the relevant words were changed from   " real property that has been used..... in the course of carrying on the business of farming in Canada and for the purposes of this definition property will be considered to have been used in the course of carrying the business of farming in Canada if... ...

20 February 1992 Administrative Letter 9202996 F- RRSP Trust — Death of Annuitant Unedited CRA Tags 146(1) spouse, 146(4), 104(6), 146(8.8), 104(13)       7-920299   D. Duff   957-8953 February 20, 1992 W. A. Mizuik     Chief Rulings DirectorateT3 Programs Section     T2 & T3 Programs Division Attention:  Aileen Wade RRSP Trusts; Tax Reporting after Death of Annuitant This is in response to your memorandum of January 29, 1992 requesting that we review your proposed reply to 24(1) After reviewing the aforementioned draft we do not see any inaccuracies in it. ...

28 February 1992 Administrative Letter 9121226 F- Cost of Capital for M & P After 85(1) Rollover Unedited CRA Tags ITR 5202, 85(1)   February 28, 1992 Application Opinions Merchandising, Manufacturing,   Section Partnerships and Trusts     Section Attention:  Sudev Basuroy G. Kauppinen 957-4363 912122 Cost of Capital for M & P This is in reply to your memorandum dated August 1, 1991 wherein you request our opinion as to the meaning of "cost of capital" for the Manufacturing and Processing Profits calculation in the following circumstances. 1.     Corporation A acquires Class 12 assets (the "assets") and claims 100% capital cost allowance thereon. 2.      ...

where the goods are delivered or payments are made; 3.     where the business assets are located; 4.      ... whether the taxpayer intended to do business in Canada; 10.      place where the assets used in the business are purchased; 11.     the degree of supervisory or other activity in Canada; 12.     the substance or object of the transaction; 13.      ...

Your Questions 1.        Would the payments made by the Company to the Canadian researchers constitute "qualified expenditures" as defined in subsection 127(9) of the Act for the purpose of claiming investment tax credit? 2.        If the payments do constitute qualified expenditures, would the reimbursement by the U.S. parent be considered either a "contract payment" or "non-government assistance" as defined in subsection 127(9) of the Act? ... For the SR & ED to be related to a business of the taxpayer, there must be some connection or link between the taxpayer's business carried on at the time the expenditure is made and the SR & ED carried on.  ...

25 July 1989 Administrative Letter 74066 F- Refundable Investment Tax Credit on SR & ED Expenditures- Qualifying Corporation Unedited CRA Tags 37, 127, 127.1(2), 248(1) specifed members   July 25, 1989 W.A. ... Bowen   957-2096 R.S. Nanner   File No. 7-4066 Subject:  Qualifying Corporation Subsection 127.1(2) of the Act We are writing in reply to your memorandum of June 26, 1989, wherein you requested our comments on whether the partners of a partnership that conducts scientific research and experimental development ("SR & ED") are entitled to the refundable investment tax credit ("RITC") in respect of the SR & ED expenditures meet the requirements of section 37 and subsection 127(9) of the Income Tax Act (the "Act") and that the partners are not "specified members" of the partnership as defined in section 248(1) of the Act. ... In our opinion, there is no RITC available under subparagraphs (a)(vi) and (vii) of the definition of RITC in respect of the SR & ED expenditures incurred by a partnership and allocated to a partner that is qualifying corporation.  ...

31 October 1989 Administrative Letter F3316 F- SR & ED Expenditures Unedited CRA Tags 37(7)(c)(ii)   October 31, 1989 Mr. ... Burnett (957-2078)   File No. F-3316 Subparagraph 37(7)(c)(ii) of the Income Tax Act This is in response to the memorandum of September 26, 1989 prepared by D. ...

8 April 1992 Administrative Letter 920302A F- Whether Sale Redeems & Acquires Includes a Deemed Disposition Unedited CRA Tags ITR 230(2), ITR 230(3) April 8, 1992 W.S. Hume Business and General Director     Division Assessment of Returns Directorate Bill Guglich (613) 957-2102 920302 Subject: T5008 Security Transactions Reporting This is in reply to your memorandum of January 24, 1991 wherein you request our views whether Regulations 230(2) and (3) require the reporting of deemed dispositions.  ...

27 October 1993 Administrative Letter 9326846 F- Minimum Tax & Net Capital Losses Unedited CRA Tags 127.52(1)(i)(ii)(A) Assessment of Returns Directorate Personal and General J.M. ... The three most obvious reasons why a taxpayer would not fully claim the net capital losses available to him in a particular taxation year are that a)     the taxpayer wishes to take advantage of the capital gains deduction under paragraph 110.6 of the Act, b)     the taxpayer's taxable income has already been reduced to nil by means of other deductions or c)     the net capital loss arises in a subsequent year and is not carried back to the taxation year in which the minimum tax arises. ...

23 March 1994 Administrative Letter 9332416 F- Japan Inhabitant's Tax — Income or Profits Tax Unedited CRA Tags 126(7) non-business income tax, IT-270R2 PRINCIPAL ISSUES: Japanese "Inhabitant's Tax"  —  Is it an "Income or Profits Tax"? ... Licardo   933241 XXXXXXXXXX This is in reply to your memorandum dated January 5, 1994, in which you asked for our comments concerning whether the Japanese "Inhabitant's Tax" would be considered an "income or profits tax" for purposes of paragraph 126(7)(c) of the Income Tax Act ("Act"). ...