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7 October 1990 Income Tax Severed Letter- Technical amendments — draft legislation on July 13, 1990 — Clause 31(8) — trusts Unedited CRA Tags none Dear Sirs: Re: Clause 31(8) Technical Amendments- Income Tax Act Draft Legislation- July 13, 1990 This is in reply to your letter dated July 19, 1990 wherein you requested our confirmation of your understanding on the above subject matter in a situation where an arriving immigrant sets up a non- resident discretionary trust and funds the trust with a loan. ...

12 December 1991 Income Tax Severed Letter 912099A F- Income of Contractors — Purchase of Contracts — IT–92R2 Unedited CRA Tags 9(1)     5-912099 Dear Sirs: Re:  Purchase of Contracts We are writing in reply to your letter of July 22, 1991 in which you requested our comments with respect to IT-92R2 entitled `Income of Contractors'. ...

8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. Paragraph l25.l(3)(a) of the Act defines M & P profit by reference to rules prescribed by regulation i.e. section 5200 and following of the Income Tax Regulations ("Regulations"). ...

16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

6 August 1980 Income Tax Severed Letter RRRR15- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

6 August 1980 Income Tax Severed Letter RRRR16- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...

14 May 1993 Income Tax Severed Letter 9313025 F- Acquisition and Disposition — Property — General Unedited CRA Tags 54(c) 248(3) 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. ...

22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(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. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...

27 January 1992 Income Tax Severed Letter 9133105- Social assistance payments — employee contractor — Respite Caregivers of the Province of Manitoba Unedited CRA Tags 56(1)(u), 56(1)(u)(iii) 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. ...

7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...