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Harris Appeals & Referrals Division 995-1723 ATTENTION P. Bush RE: 1979 Notice of Objection This is in response to your memorandum dated December 7, 1982 regarding XXXX Notice of Objection relating to the inclusion of storage (lay-away) sales in its income for the 1979 taxation year. ...

., would be precluded from deducting the moving expenses by subparagraph 62(1)(a)(i) of the Act. (2) & (3) the individual in these situations would not be disqualified for a housing loan provided that he was able to establish that he was ordinarily employed in Canada and was entitled to a deduction under section 62 of the Act. (4) Assuring that this situation refers to a loan made to an individual at the time when he was both resident and employed outside Canada, the loan would not qualify as a housing loan as defined by paragraph 80.4(2) (b) of the Act unless such a loan was made to enable or assist him to acquire a dwelling for his habitation if the acquisition of that dwelling was made in the course of a change in his residence from a place outside of Canada to a place within Canada. ...

In contrast, the response to the direct request to define "operating costs" as reported in the Commons Debates of March 10. 1983 was "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road"; a statement which could be used to support the Department's position. ...

Dans le dictionnaire Law & Commercial Dictionary de West'6 ce terme est défini comme étant: "In contracts, the benefit or advantage which the promisor is to receive from a contract is the inducement for making it. ...

Blackburn, Director Planning & Administration Branch October 25, 1989 Dear Sirs: Re: Proposed Policy on Self-Funded Leave (the "Plan") This is in reply to your letter of September 21, 1989. ...

Nos commentaires De façon générale, nous sommes d'opinion qu'un prêt à recevoir inter-compagnie entre corporations liées n'est pas "... un élément d'actif utilisé dans une entreprise que la corporation ou une corporation qui lui est liée exploite activement... ...

28 September 1989 Income Tax Severed Letter AC32558- Taxable Preferred Share- Dividend or Liquidation Entitlement Established to be not Less than Minimum Amount September 28, 1989 Leasing & Financing Section Blair P. ...

Finally, you have suggested that line 32 of form T691(E) "Calculation of Minimum Tax " is misleading. ...

Clark Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

XXXX Comments & Observations Paragraph 8(1)(b) states, in part, that "(1) In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted... ...