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28 July 1992 Administrative Letter 9220946 F- Scientific Research One Pool Or Many Pools Unedited CRA Tags 37(1)(a), 37(1)(d)      922094      C.R. Bowen     957-8585 July 28, 1992 Appeals and Referrals Division10th floor, 88 Metcalfe Attention: Jim NordinSection Chief 24(1) Pooling Concept under Section 37 We are writing in reply to a memo from S.D.S. ...

Bowen Appeals and Referrals (613) 957-2096 Division   File No. 8-0306 J. ... 5.     Is a stone slinger eligible for ITC as qualified construction equipment? ... As a result, the amount of M & PP eligible for the reduced rate of tax would be calculated according to the following formula: M&PP = MC + ML   x adjusted business income     C + L MC =  Cost of M & P capital C = Cost of capital ML =  Cost of M & P labour L = Cost of labour All of these terms are defined in section 5202 of the Regulations. ...

I.                    24(1) II.               24(1) III.               24(1) During our telephone conversation, you requested that we provide you with our comments regarding the past transactions detailed in your letter. ...

They also advised against tax avoidance, but suggested proper planning of your financial affairs.       ... (5)     19(1) under section 216 of the Canadian Income Tax Act.      QUESTION:  If you return to Canada, you are concerned as to your income tax obligations on your return.  ... E.     Since the house qualifies as taxable Canadian property there will be no deemed acquisition of property when you become a resident of Canada.       ...

3)     In the case of charitable giving, could an annuity be structured as follows?:-      Owner would be the donor-      The interest income would continue to the donor during his lifetime-      The charity would be named an irrevocable beneficiary on the contract so at death the capital of the contract would go to the charity. ... There it states,      "Where property is held in trust for the benefit of one or more persons it is the Department's view that such property normally vests indefeasibly in the trust and not in a beneficiary thereof.  ...

The contracted rate for the mortgage loan between the employee and the lending institution is 8.75%. 2.     The employee pays interest a the rate of 6.75%. 3.     The remaining interest cost (2%) is paid to the lender by the employer, through an arrangement agreed to at the inception of the loan. 4.      ... In examining the benefit deemed to have been received by the employee as computed in subsection 80.4(1) of the Act, you have arrived at a benefit of  2.25%, rather than 2%, of the principal amount: Paragraph 80.4(1)(a): 9%   80.4(1)(b): 2%   80.4(1)(c): 8.75%   80.4(1)(d): Nil Then (a) + (b)- (c)- (d) gives 11%- 8.75% = 2.25% In other words, this suggests a taxable benefit to the employee based on 2.25%, notwithstanding that the employer subsidy results in the employee paying an effective interest rate which is only 21 less than the market rate charged by the lender. ...

13 September 1990 Administrative Letter 901946 F- Indian Band Council Considered Canadian Municipality Unedited CRA Tags 110(1)(a)(iv), 118.1(1) total charitable gifts   19(1) 901946   Bill Guglich   (613) 957-2102   EACC9656 September 13, 1990 19(1) In a letter dated July 24, 1990, Ms. ...

Answer: My reply to19(1) was based on the following: General Comments 1.      ... This could be relevant where the taxpayer is not exempt from Canadian tax on such remuneration (ie. there would be Canadian tax attributable to that source  —  126(3)). 3.      ... The meaning of the word "official" in this regard is described in paragraph 5 of IT-397R. 5.      ...

12 July 1991 Administrative Letter 910926 F- Interest Deductibility Unedited CRA Tags 20(1)(c)   910926   M.P. Sarazin   (613) 957-2125   July 12, 1991 Dear Sirs: This is in reply to your letter dated April 1, 1991 wherein you requested a technical interpretation regarding the application of paragraph 20(1)(c) of the Income Tax Act (Canada) (the "Act") to the following situation. Facts 1. 2. 3. 4.     24(1) 5. 6. You have requested that we consider the impact of the Department of Finance Information Release 90-171 dated December 20, 1990 and titled "Tax Rules for Deductibility of Interest Extended" (the "Finance Release") and paragraph 7 of Interpretation Bulletin IT-445 in the preparation of our response. ...

25 July 1990 Administrative Letter 900616 F- Meaning of "Trader or Dealer in Securities" Unedited CRA Tags 39(4), 39(5)   July 25, 1990 Appeals Branch Business and General   Division   Bill Guglich   957-2102 Dave Turner Appeals and Referrals EACC9394   900616 SUBJECT: 19(1) Paragraph 5 of IT-479R This is in reply to your memorandum of May 3, 1990 concerning the Department's interpretation, in paragraph 5 of IT-479R, of the term "trader or dealer in securities". ...