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21 October 1991 Ministerial Letter 912658 F- Change in Use of Real Property Unedited CRA Tags 45(1), 45(2) Dear Sirs: Re:  Change in use of Real Property This is in reply to your letter of August 29, 1991 concerning the application of the change in use rules in subsections 45(1) and (2) of the Income Tax Act (the "Act") to the series of transactions described below. Facts 1.      2.                       24(1) 3.      Issues l.        Is a life estate in real property an eligible capital expenditure as defined in paragraph 14(5)(b) of the Act. 2.        ...

In particular condition No 2, that the shares of the corporation are held by an individual or an individual and persons (other than a corporation) related to the individual, is not met.  ... Furthermore, the funding of the corporation in the manner proposed may not be acceptable. 2.      ... The same situation as 2. except the corporation is controlled by the parents, Mr. and Mrs. ...

2)     Are manufacturers' rebates, such 85 those offered by auto and appliance retailers, required to be included in the income of the purchaser of such products? ... For the purposes of our comments, we have taken the word "consumer" to mean an individual person subject to Canadian income taxes who is acquiring the property in question for his own personal use and who will not 1) be using the property in the course of carrying on a business, 2) be earning income, such as rental or leasing income, from that property or 3) be holding on to that property for the purpose of selling it at a profit.  ... If you have a particular fact situation which is of concern to you, you may wish to call your nearest District Office or to write to our office outlining the specific details of the arrangement. 2)     A manufacturer's rebate received by a consumer on the sale price of merchandise acquired by the consumer should not be included in the income of the consumer for income tax purposes. ...

Bowen   (613) 957-2096 19(1) EACC9664 September 11, 1990 Dear Sirs: Re:  Scientific Research and Experimental Development ("SR&ED") We are writing in reply to your letter of June 15, 1990, wherein you requested our comments on 1) the deductibility of SR&ED expenses under paragraph 18(1)(a) of the Income Tax Act (the "Act") and 2) the availability of investment tax credit ("ITC") to a company performing SR&ED activities on behalf of another taxpayer. ... 2.     Where a limited partnership, which chooses to deduct its SR&ED expenditures under paragraph 18(1)(a) of the Act, has entered into an agreement with a company under which the company will carry on SR&ED activities on behalf of the partnership, will that company be entitled to ITC on such SR&ED expenditures? ... Such expenses allowed to be deducted by a partnership in calculating its income would not be subject to the restriction in paragraph 96(1)(g) of the Act. 2.      ...

LP is a limited partnership that is registered as such under the laws of the relevant provincial jurisdiction. 2.      ... (c)  Since a partnership is by definition "... the relation that subsists between persons carrying on business in common with a view to profit" (paragraph 2 of IT-90) it is our view that the sale of assets to a corporation by the LP followed shortly thereafter by a sale of the capital shares by the LP could also be an adventure in the nature of trade.  The income derived by the LP from the disposition of shares could be business income of the LP and allocated to the individual partners under paragraph 96(1)(f) of the Act. 2.      ...

Subsection 251(3) provides:      Where two corporations are related to the same corporation  within the meaning of subsection (2), they shall, for the purposes of subsections (1) and (2), be deemed to be related to each other. ... Subsection 251(3) only deems two corporations to be related to each other for the purposes of subsections 251(1) and (2), i.e. it does not apply for the purposes of subsection 251(3).  ...

2.        If the employee lives and works in an area where the employer does not have a business establishment, is the distance driven between the employee's residence and the location of the first customer and the distance driven from the location of the last customer back to his residence considered to be personal use? ... For comments on this definition, you may refer to paragraphs 2 and 3 of the enclosed Interpretation Bulletin IT-63R3, a publication which discusses the various benefits derived from the use of a company vehicle. ... Where the employer does not provide a business establishment with respect to an employee and the employee is entitled to claim expenses in respect of an office in the employee's home as discussed in paragraphs 2, 3, and 10 of IT-352R, it is our view that the settled place of work is the home. ...

ASSOCIATE DEPUTY MINISTER'S OFFICE (1) ADM'S OFFICE (2) # 97-04132M PENDING COPY RETURN TO INCOME TAX RULINGS AND INTERPRETATIONS DIRECTORATE 15TH FLOOR, ALBION TOWER Signed on July 14, 1997 XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to reply to your letter of June 18, 1997, wherein you suggested that tax relief be provided to help the victims of the Red River Flood disaster finance the rebuilding of their homes. ... Sarazin 957-3499 971691 July 2, 1997 ...

" Deputy Minister’s Office (2) Assistant Deputy Minister’s Office (2) Pending Copy Return to Rulings, 15th Floor, Albion Tower March 18, 1998 XXXXXXXXXX Dear XXXXXXXXXX: Thank you for forwarding a copy of your correspondence dated February 13, 1998, sent to Mr. ...

26 July 1993 Ministerial Letter 9319018 F- IT-372R Paragraph 4 Canadian Residence Unedited CRA Tags 212(1) DM'S OFFICE (2) M93-3845T ADM'S OFFICE (3) RETURN TO RULINGS, ROOM 303, MET. ... It is possible that the trust in question may, in fact, be a resident of Canada, and in this regard I refer you to the comments in paragraph 2 of Interpretation Bulletin IT- 447, a copy of which is enclosed for your information. ...