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30 August 1984 Income Tax Severed Letter A-0349- [Employee Compensation & Benefit Plan] R.J. Macdonald (613) 995-0051 XXXX August 30, 1984 Dear Sirs: Re: Employee Compensation & Benefit Plans This letter is in reply to your letter dated August 16, 1984 in which you asked us to confirm that a particular plan for payment of health care expenses is a private health services plan as the term is defined at paragraph 110(8)(a) of the Income Tax Act (the "Act"). ...

12 December 1991 Income Tax Severed Letter 913289A F- Canada – Switzerland Income Tax Convention Unedited CRA Tags Treaty Switzerland Article 5, Paragraph 3 Canada – Switzerland Tax Convention Article V, Paragraph 3            This is in reply to your memos dated November 28 and December 3, 1991 regarding the above matter.  ... Paragraph 3 of Article XV of the Canada – Switzerland Tax Convention (the "Convention") states that, notwithstanding the preceding provisions of that Article (Dependent Personal Services), remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State. ...

12 August 1996 Income Tax Severed Letter 9626227 F- XXXXXXXXXX — depenses RS&DE Unedited CRA Tags 37(8)(d) 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. ... Pour son exercice se terminant le XXXXXXXXXX (le «contribuable») a réclamé XXXXXXXXXX $ de dépenses en capital qu'il a engagées pour des activités de recherche scientifique et de développement expérimental («RS&DE») exercées au Canada. Du montant de XXXXXXXXXX $, une somme de XXXXXXXXXX $ est attribuable à des dépenses relatives à la construction d'un laboratoire. 2. ...

11 March 1996 Income Tax Severed Letter 9605565- Disability — lump sum Unedited CRA Tags 6(1)(f) 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. ... MNR [] 87 DTC 268 and Marchand v. MNR [] 87 DTC 630. In the Peel case, the taxpayer received a lump sum in settlement of his rights under the insurance contract. ...

23 May 1990 Income Tax Severed Letter RRRR337 F- Interprétation relativement à la vente d'un prototype — recherche et développement Unedited CRA Tags 37 xxxxx 5-900496 J.P. Simard (613) 957-8953 ' l'attention de xxxxx Le 23 mai 1990 Messieurs, Objet: Recherche et développement La présente est en réponse à votre lettre du 13 avril 1990 demandant notre interprétation relativement à la vente d'un prototype. ...

31 October 1989 Income Tax Severed Letter AC58322- SR & ED- Approved Association or Research Institute R. Albert (613) 957-2098 19(1) October 31, 1989 Dear Sirs: Re: Subparagraph 37(1)(a)(ii) of the Income Tax Act (the "Act") We are writing in reply to your letter of July 7, 1989 and subsequent telephone discussion concerning the taxation implications of the provisions of subparagraph 37(1)(a)(ii) of the Act. 19(1) Clause 37(1)(a)(ii)(E) of the Act provides for the deduction of payments made to "an approved organization that makes payments to an association, institution or corporation described in any of clauses (A) to (C)" to be used for scientific research and experimental development ("SR & ED") carried on in Canada, related to a business of the taxpayer, and provided that the taxpayer is entitled to exploit the results of such SR & ED. ... The Assistant Deputy Minister of Revenue Canada, Taxation will grant approval to an association or an institute if it meets the following criteria: a) it has the facilities and personnel capable of carrying out SR & ED, b) it carries on only activities that are unquestionably SR & ED, c) the typical requirements for non-profit status are satisfied, such as no personal benefit to members, no control of other associations, satisfactory provisions for distribution of assets on dissolution, etc., d) the general public will be a beneficiary of the results of successful SR & ED, and e) the funding of the organization will be sufficient to ensure continued research by it. ...

18 December 1989 Income Tax Severed Letter AC74225- SR & ED Qualifying Expenditures W.A. ... Our interpretation of those requirements is as follows: a) Clause (A) includes an expenditure which is incurred for and all or substantially all of which is attributable to the prosecution, or to the provision of premises, facilities equipment for the prosecution, of SR & ED in Canada: Paragraph 37(7)(b) of the Act defines SR & ED as having the meaning given by subsection 2900(1) of the Regulations. ... Thus to qualify under clause (A) an expenditure must be both incurred for and 90% or more attributable to SR & ED as defined in subsection 2900(1) of the Regulations. ...

9 June 1997 Income Tax Severed Letter 9714705- Twenty one year rule — see 970488 Unedited CRA Tags 104(4), 159(6.1) SUMMARY: 21-year rule – see ^CAIXRCV 970488—ITA-104(4), 159(6.1)—Response to taxpayer request to amend the Income Tax Act to grandfather certain pre-1972 trusts from the 21-year deemed realization rule in subsec. 104(4) of the Income Tax Act. ... REASONS: Taxpayer has option to apply to provincial court to have the trust varied & property distributed under 107(2); alternatively subsection 159(6.1) allows trusts election to spread payment of taxes arising on deemed disposition over 10 years charging interest at the prescribed rate. 971470 XXXXXXXXXX L. ...

The following is a brief summary of the guideline: • The funder must be a principal in the new business to be carried on in the year. It must be legally possible for a funder to carry on such a business as a principal. • The funder must have rights to commercially exploit any resulting products and/or processes. However, a funder may license the right to use to another party in exchange for a share of gross or net revenue for an unlimited term or a term approximating the expected useful life of the resulting product or process. • The proportionate share of revenue to the funder must represent a reasonable expectation of profit. • The funder must not be guaranteed a return of his principal and/or revenue. ...

25 July 1989 Income Tax Severed Letter AC74066- Refundable Investment Tax Credit on SR & ED Expenditures- Qualifying Corporation July 25, 1989 W.A. ... Nanner Subject: Qualifying Corporation Subsection 127.1(2) of the Act File: 7-4066 We are writing in reply to your memorandum of June 26, 1989, wherein you requested our comments on whether the partners of a partnership that conducts scientific research and experimental development ("SR & ED") are entitled to the refundable investment tax credit ("RITC") in respect of the SR & ED expenditures meet the requirements of section 37 and subsection 127(9) of the Income Tax Act (the "Act") and that the partners are not "specified members" of the partnership as defined in section 248(1) of the Act. ... In our opinion, there is no RITC available under subparagraphs (a)(vi) and (vii) of the definition of RITC in respect of the SR & ED expenditures incurred by a partnership and allocated to a partner that is qualifying corporation. ...