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7 November 1990 Income Tax Severed Letter- Manufacturing & Processing Profits Deduction Unedited CRA Tags 125.1, IT-145R Subject: XXX Manufacturing & Processing (“M&P”) Profits Deduction We are writing in reply to your memorandum of April 19, 1990, wherein you requested our comments as to whether or not the activities of the above-noted taxpayer qualify for the M&P profits deduction under section 125.1 of the Income Tax Act (the “Act”). ...

28 March 1990 Income Tax Severed Letter AC74599- Recent Issues — OECD Working Party No. 6 Unedited CRA Tags none March 28, 1990 Provincial & International Specialty Rulings Relations Division Directorate H.K. ... Example A.1- Domestic merger where the acquired corporation has a p/e in another country (See paragraphs 13 to 15 of the Note) Scenario This scenario deals with two corporations (ACo & BCo) both of which are resident in Country X. ...

A taxpayer who contracts with another person in order that this person performs SR & ED on his behalf and who pursues no activities, other than (1) retaining the rights pertaining to any results from the SR & ED performed and (2) commercializing these rights or results, cannot be said to derive substantially all of his revenue from the prosecution of SR & ED carried out by him, within the meaning of paragraph 2902(a) of the Regulations. ... It is our view that revenue arising from the prosecution of SR & ED generally envisages the provision of scientific research for a fee or a sale of the know-how developed, i.e. the rights. Whether paragraph 37(7)(e) of the Act would apply in a particular case would depend on whether or not the taxpayer can be said to derive all or substantially all of his revenue from the prosecution of SR & ED. ...

23 February 1989 Income Tax Severed Letter 5-7409-   R. Albert (613) 957-2098 FEB 23 1989 Dear Sirs: Re: Scientific Research and Experimental Development ("SR & ED") Non-Government Assistance and Contract Payments We are responding to your November 30, 1988 request for an interpretation as to whether service fees payable by a foreign affiliate to a Canadian taxpayer would be considered as non-government assistance or a contract payment which would reduce the qualified expenditures made for purposes of calculating the investment tax credit ("I.T.C. ... The fee is determined by NRCo's share of the SR & ED expenditures incurred by Canco based on the ratio of NRCo's sales to worldwide related group sales, as in a typical cost-sharing arrangement. c) Canco retains all Canadians rights. NRCo has the exclusive right to use the results of the SR & ED worldwide, with the exception of Canada, at no additional charge. d) NRCo does not carry on business in Canada. ...

27 June 1989 Income Tax Severed Letter AC57919- Corpotation Qualifying as "Non-profit Corporation" for SR & ED 57919 C.R. ... Prior to the incorporation of a non-profit corporation for scientific research and experimental development, the Department is prepared to rule on whether or not the corporation when incorporated will be "constituted exclusively for the purpose of carrying on or promoting "SR & ED" for the purpose of paragraph 149(1)(j). ... However, the Department can provide an opinion, which is not binding on the Department, as to whether, based on the assumption that the corporation does qualify under paragraph 149(1)(j) of the Act, the payments made to the corporation by contributors will be deductible under subsection 37(1) of the Act if the taxpayer carries on a business in Canada, the payments are to be used for SR & ED carried on in Canada which is related to a business of the taxpayer, and the taxpayer is entitled to exploit the results of such SR & ED. ...

All copies are then to be sent to the RRSP issuer or RRIF carrier from which the property is to be transferred (the Transferor). • Part III of all copies is to be completed and signed by the Transferor who shall keep Copy 4 and send Copies 1, 2 and 3 to the Transferee along with the funds or property being transferred. • Part IV of Copies 1, 2 and 3 is to be completed and signed by the Transferee. ... DEFINITIONS • "Individual Plan No." and "Individual Fund No. ... This includes a duly appointed agent of such a person. • "RRIF carrier" means a person described in paragraph 146.3(1)(b). ...

5 March 1986 Income Tax Severed Letter 6013-2- [Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures] Unedited CRA Tags 67, 245(1), 37(1), 194(2) Decision Summary Scientific Research Section Subject: Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures Reference: 67, 245(1), 37(1) and 194(2) Issue: Do 67 and 245(1) apply to 37(1)(a) and 37(1)(b) amounts claimed as a Part VIII refund under 194(2)? ... Decision: To accept the legal opinion that 67 and 245(1) apply to R & D expenditures claimed as a Part VIII refund as defined in 194(2). ...

20 October 1989 Income Tax Severed Letter AC80320- D & B Oilfield Contracting Ltd.- Adverse Decision E. ... Angus 8-0320 RE: D & B OILFIELD CONTRACTING LTD. ADVERSE DECISION- TAX COURT OF CANADA This is in reply to the memorandum of September 20, 1989. ...

19 April 1990 Income Tax Severed Letter 900259- Self-directed RRSP — Mortgage as Qualified Investment Unedited CRA Tags 146(1)(g), Reg. 4900(1)(j), 4900(4) This is in reply to your letter of March 27, 1990 concerning the above-mentioned subject. ... As outlined in paragraph 8 of Interpretation Bulletin IT-320R, (special Release dated May 25, 1984) other requirements to be met include • the amount of the mortgage interest rate and other terms must reflect normal commercial practice, and • the mortgage must be administered as if it were on property owned by a stranger. ...

7 June 1990 Income Tax Severed Letter AC74847- Oil & Gas Steering Committee Unedited CRA Tags none Special Audits Division Resource Industries E.H. ... Gauvreau 957-8953 7- 4847 Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ...