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19 July 1996 External T.I. 9623625- PATRONAGE ALLOCATIONS / DIVIDENDS Unedited CRA Tags 135(7) 125(1) 125.1 20(1)(v.1) 1204R 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. ... " In another speech given at the same tax conference (reproduced at pages 18 and 19 of the aforementioned book) Mr. ...

19 November 1996 External T.I. 9737005- INVESTMENT MANAGEMENT FEES OF RRSP & RRIF Unedited CRA Tags 20(1)(bb) 146(1) 146.3(2)(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. ... Principal Issues: RRSP & RRIF investment management fees Position: Confirming and elaborating on our standard position that investment management fees paid by annuitant are considered payment of a premium to RRSP to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

2 December 1996 External T.I. 9621265- ALTERNATE & SPARE PARTS. Unedited CRA Tags CLASS 34 CLASS 43.1 18(1)(A) 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. ... Principal Issues: Whether alternate and spare parts could be included in Class 34 & 43.1? ...

5 May 1995 External T.I. 9430895- CHILD CARE EXPENSE FOR UI RELATED BUSIN & EMPL INCOME Unedited CRA Tags 63(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. ... Principal Issues: whether UI benefits received in conjuction with the self employment assistance program or the Unemployment Insurance Job Creation Program-section 25 qualify as earned income for purposes of the child care expense limitation Position TAKEN: no Reasons FOR POSITION TAKEN: the amounts received are benefits under the UI Act & are not in connection with the cost of a course or program designed to facilite re-entry into the labour force Youth Programs and Services Human Resources and Development Canada 4th Floor, Place du Portage, Phase IV 140 Promenade du Portage A. ...

29 June 1995 External T.I. 9505455- FLEX PLANS & CONVERSION OF SALARY TO CREDITS Unedited CRA Tags 5 56(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. ... Principal Issues: 1. conversion of salary & other taxable amounts to flex credits 2. cash out of credits to a health spending account Position TAKEN: 1. taxable at the time of conversion under 56(2) and 5(1) 2. cash out provision disqualifies a health spending account as a phsp Reasons FOR POSITION TAKEN: 1. ...

17 July 1995 External T.I. 9500075- VACATION BUYING & SELLING IN A FLEX PLAN Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: whether a flexible benefit plan which permits the purchase of vacation will be considered a salary deferral arrangement Position TAKEN: question of fact Reasons FOR POSITION TAKEN: if a plan permits the carryforward of purchased vacation, such a plan could be a SDA depending on whether the potential tax deferral associated with such a carryforward can be considered one of the main purposes of the arrangement & thus we will not rule or offer an opinion. ...

14 September 1995 External T.I. 9515775- FAMILY MORTGAGE PLAN ARRANGEMENT- 56(2) & 56(4) Unedited CRA Tags 56(2) 56(4) 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. ... Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

22 November 1995 External T.I. 9518245- SCC EGAN & EFFECT ON SAME SEX PARTNERS HEALTH PLAN Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: details on how to segregate one plan so that the part that qualifies as phsp will not be considered an ebp & whether SCC decision in Egan v the Queen will impact on our position Position: separate plans require no cross-susidization-the SCC decision upholds the OAS extended def'n of spouse so there is no reason to believe that the ITA distinction would offend the Charter Reasons: see above A. ...

3 January 2002 External T.I. 2001-0067955- Application of 75(2) & 107(4.1) to a trust Unedited CRA Tags 75(2) 107(4.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

16 May 2002 External T.I. 2002-0135765- E-Commerce & Computer Software Unedited CRA Tags 212(1)(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 CCRA. ... Position Paper Internet Commerce, which evolved from 2 sources:- a 1998 CCRA Technical Advisory Group (TAG) on Interpretation & International Cooperation; and- The "Taxation Framework Conditions", agreed upon in Ottawa in 1998 by member countries of the OECD. 2. ...