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PRINCIPAL ISSUES: % ownership and amount being financed by DPS. POSITION: Give rulings. REASONS: Only % holding of debt being refinanced. XXXXXXXXXX XXXXXXXXXX 960884 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX We are writing in response to your letter dated XXXXXXXXXX wherein you requested an advance income ruling on behalf of the above-noted taxpayers. ...

The definition of "cumulative gains limit" and the relevant portion of the "annual gains limit" read as follows: ""cumulative gains limit" of an individual at the end of a taxation year means the amount, if any, by which (a) the total of all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 for A in the definition "annual gains limit", or (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (a) of the definition "annual gains limit" as it read in its application to those years exceeds the total of (b) all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 under paragraph (a) or (b) of the description of B in the definition "annual gains limit", (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (b) or (c) of the definition "annual gains limit" as it read in its application to those years, or (iii) an amount deducted under paragraph 3(e) by the individual for the individual's 1985 taxation year, (c) all amounts deducted under this section in computing the individual's taxable income for a preceding taxation year, and (d) the individual's cumulative net investment loss at the end of the year;" The description of "B" in the formula A- B found in the definition of "annual gains limit" reads in part, as follows: "B is the total of (a) the amount, if any, by which (i) the individual's net capital losses for other taxation years deducted under paragraph 111(1)(b) in computing the individual's taxable income for the year exceeds (ii) the amount, if any, by which the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses exceeds the amount determined for A in respect of the individual for the year, and b) all of the individual's allowable business investment losses for the year; " (emphasis added is ours) Note that the definitions of "annual gains limit" and "cumulative gains limit" as they read prior to the 1993 amendments would yield the same result provided that none of the gains or losses in question relate to non-qualifying real property. ...

Harding A/Manager, Policy & Technical Services 957-8953 Trust Accounts Division Attention: Lloyd MacKay 2000-001003 Retirement Compensation Arrangements ("RCAs") This is in reply to your memorandum of February 23, 2000, in which you asked us to respond to comments received by you with respect to our memorandum to you dated January 17, 2000, (our file 1999-001524). ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1-... ...

Government Assistance Issue The issues are twofold and relate to the position taken in our file # 9809735: 1. whether subsection 127(18) of the Act applies to net government assistance against the SR&ED qualified expenditures only where the government assistance is provided with respect to the construction of a building which will be used primarily for SR&ED, or whether it may also apply where the building will be dedicated primarily to manufacturing but in which substantial SR&ED will be performed, and 2. where the assistance (or a large portion thereof) is received and the building is constructed prior to the commencement of the SR&ED, whether the assistance which can be attributed to the SR&ED is to be netted in its entirety against the SR&ED qualified expenditures in the year such expenditures are first incurred, even if the result is a negative pool balance. ...

13 April 1992 Income Tax Severed Letter 9207126- Ontario Employee Wage Protection Program April 13, 1992 Other Returns & Guides Division Financial Industries Division P. ...

As a result of this calculation, the capital gain to be included in income from a 1992 disposition of a principal residence which has been owned since 1971 and which has been designated to be a principal residence for the taxation years 1988-1992 inclusive (for example, the years in which the deeming provision does not apply) would be the capital gain calculated in the normal manner for property held on Valuation Day (V-Day) less 6/21 (5+1 / 21) of the capital gain otherwise calculated. ...

Taxpayer, as calculated pursuant to paragraph 40(2)(b) of the Act, is as follows: $350,000- ($350,000 x (1+10)/15)= $350,000- $256,667 = $93,333 7. ...

We suggest the following wording: " A key element to qualifying as a non-profit organization is that the organization must not have profit as an objective. ...

29 September 1989 Income Tax Severed Letter AC73788- Discount on Obligations and Foreign Exchange Losses on Repayment September 29, 1989 MONTREAL District OFFICE HEAD OFFICE Remi St-Louis Bilingual Services & Resource Audit Section Industries Division Section 148 M. ...