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11 December 1991 Income Tax Severed Letter 9123365- Person Related to the Employer — Two Partnerships 24(1) 5-912336 D.S. Delorey (613) 957-8953 Attention: 19(1) December 11, 1991 Dear Sirs: Re: Related Person — Partnership This is in reply to your letter of August 20, 1991 concerning the reference in subparagraph 60(j.1)(ii) of the Income Tax Act (the "Act") to the term "or a person related to the employer". ...

10 April 1992 Income Tax Severed Letter 9208575- Forgiveness of debt — daylight loan Unedited CRA Tags 80(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 paragraph goes on to state that this rule will also apply where these results are achieved through a series of transactions and gives the following example: "... where a corporation borrows money from a bank or lender on a daylight loan basis to pay the amount of a debt to its creditor and the creditor then uses the funds to buy shares in the corporation which in turn repays the daylight loan, section 80 will be applicable if the principal amount of the debt extinguished exceeds the fair market value of the shares acquired by the creditor. ...

24 April 1992 Income Tax Severed Letter 9211087- 21-year deemed realization rule — accumulating income Unedited CRA Tags 104(4), 104(14), 104(21), 108(1)(a), 104(5.3) 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. ... SUBJECT: 21-YEAR DEEMED REALIZATION RULE, ACCUMULATING INCOME SECTION: 104(4), 104(14), 104(21), 108(l)(a), 104(5.3)] PRAIRIE TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 15 Under the proposed trust rules issued by the Department of Finance on December 20, 1991, a trust, that does not have any exempt beneficiaries or has not previously made an election under proposed subsection 104(5.3) and that is not a pre-1972 spousal trust at the end of the year and is not described in proposed revised paragraph 104(4)(a), is deemed to dispose of all its capital property (other than excluded property or depreciable property) and land included in the inventory of the trust for proceeds equal to their fair market value on the 21st anniversary date of the trust. ...

8 March 1990 Income Tax Severed Letter AC74595- Patent Costs & Legal Fees Considered Capital or Income Expenditures Unedited CRA Tags 18(1)(b), Reg. ... Day Audit Division (613) 957-2136 Re: Patent Costs & legal Fees 7-4595 Capital or Income Expenditures We are writing in reply to your memorandum of December 18, 1989, wherein you requested our views regarding the deductibility of certain patent costs and legal fees incurred by a taxpayer in the following situation. 24(1) Our Comments We have reviewed your submission, along with the relevant documentation. ...

27 January 1992 Income Tax Severed Letter 9119055- Acquisition of property — change in beneficial ownership Unedited CRA Tags 54(c)(v), 245(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. ... However, we feel that the following issues does need careful consideration: • where beneficial ownership resides, and- whether transactions are subject to general anti-avoidance rules. ...

3 April 1992 Income Tax Severed Letter 9209557- Old flow-through share partnership — allocation of Canadian exploration expenses Unedited CRA Tags 66.1(6)(a)(v), 66.1(6)(a)(iv) 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. ... Partnerships 7-920955- 66.1(6)(a)(iv) & (v) March 31, 1992 This request is for comments with respect to a strictly technical argument that a partnership's CEE earned under a flow-through share agreement pursuant to subparagraph 66.1(6)(a)(v) is CEE of the partnership solely by virtue of that subparagraph. ...

1 October 1996 Income Tax Severed Letter 9631835- Farming — mandatory inventory adjustment Unedited CRA Tags 28(1.2) 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. ... Hence, the value of the inventory would be the "cash cost" or original cost of $42,000 ($40,000 + $2,000). ...

13 May 1988 Income Tax Severed Letter 5-5852- Principal Residence Subjacent & Contiguous Land in Excess of One-half Hectare XXXX 92429 92490 R. ... Day (613) 957-2136 MAY 13 1988 XXXX Re: Principal Residence Subjacent & Contiguous Land in Excess of One-half Hectare The Queen v. ...

30 April 1985 Income Tax Severed Letter 7-3785- [Reg. 1205(1) (b)—Class 10(k)—Tailings Pipes & Power Distribution Systems] April 30, 1985 HEAD OFFICE Resource Industries Section D. Lanos (613) 993-6201 RE: Reg. 1205(1) (b)- Class 10(k) Tailings Pipes & Power Distribution Systems This is in reply to your memorandum dated December 21, 1984 concerning the classification of the following assets used by XXXX in its mining operations in the above taxation years: 1) tailings pipes used to transport waste products from the smelter and refinery to the tailings pond; and 2) power distribution systems located at the mine site including power lines, underground cables, electrical substations, transformers, generators, circuit brakers and ancillary electrics. ...

2 June 1986 Income Tax Severed Letter 5-1367- [] XXXX G. Kauppinen (613) 995-0051 June 2, 1986 Dear Sirs: This is in reply to your letter dated March 25, 1986 concerning sub- paragraph 146(3)(b)(iii.l) of the Income Tax Act ("Act"). ... In developing these variable rate annuities, you have asked our opinion as to whether an interest rate on guaranteed investment certificates ("GIC's "), term deposits or mortgages offered by a credit union to its members or by a trust company, XXXX, would qualify as a "generally available Canadian market interest rate". ...