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28 April 1986 Income Tax Severed Letter 5-1065- [] XXXX J.D. Brooks (613) 957-2118 XXXX April 28, 1986 Dear Sirs: This is in reply to your letter of February 6, 1986 in which you requested our opinion concerning the change in control of a corporation. ...

22 August 1986 Income Tax Severed Letter 5-1628- [] XXXX A.A. Cameron (613) 957-2121 XXXX August 22, 1986 Dear Sirs: Re: Technical interpretation requested concerning subsection 111(5) of the Income Tax Act (the "Act") We apologize for the delay in responding to you letter of May 16, 1986 in which you requested our interpretation of the above-mentioned provision of the Act in a situation where control of a corporation has changed in a taxation year and that corporation had available at that time a non- capital loss from a prior taxation year which had arisen due to a legitimate allowable business investment loss sustained in that prior taxation year. ...

3 February 1988 Income Tax Severed Letter 5-5287- [] XXXX R. Nanner (613) 957-3494 February 3, 1988 Dear Sir: We are writing in reply to your letter of December 16, 1987 concerning transferability of a commuted registered retirement savings plan (RRSP) annuity to a registered retirement income fund (RRIF) pursuant to subsection 146(16) of the Income Tax Act (the "Act"). ...

24 March 1986 Income Tax Severed Letter 5-1210- [] XXXX (A-2052) C. Kauppinen (613) 995-0051 March 24, 1986 Dear XXXX This is in reply to your letter dated March 3, 1986 which is further to our letter of February 18, 1986 regarding the potential application of paragraph 204.2(1)(b) in a situation in which an annuitant of a self-directed RRSP directs XXXX as trustee of the plan, to invest in a mortgage where the annuitant under the plan is the mortgagor. ...

20 May 1986 Income Tax Severed Letter 5-1325- [] Mr. G.E.. Racine Chief Advisory Services Pay Products Group Accounting, Banking and Compensation Directorate Supply and Services Canada Ottawa, Ontario K1A OS5 G.D. ...

13 February 1992 Income Tax Severed Letter 9119225- Computer software royalties — “rentals” Unedited CRA Tags 212(1)(d), Canada–U.S. ... Saint John Shipbuilding & Dry Dock Co. Ltd. [[1980] C.T.C. 352] 80 D.T.C. 6272 ("Saint John Shipbuilding"), at 6275 where Judge Thurlow states that "The word "rental" is not a familiar one to use in connection with property rights of the kinds enumerated but I see no reason to think that when used in reference thereto it would connote characteristics different from those it has in its more familiar use in relation to tangible property. ...

31 May 1989 Income Tax Severed Letter 5-8011- Meaning of the words “... where, in contemplation of and before the transfer, property has become property of the particular corporation...” in the midamble of paragraph 55(3)(b) Unedited CRA Tags 55(3)(b) Dear Sirs: This is in reply to your letter of April 19, 1989, in which you requested our views concerning the meaning of the words "... where, in contemplation of and before the transfer, property has become property of the particular corporation... ...

15 May 1996 Income Tax Severed Letter 9608427- Tuition tax credit — university outside Canada Unedited CRA Tags 118.5 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. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

17 March 1990 Income Tax Severed Letter RRRR301- Review of Corporate Reorganizations Course Material — Lesson 3 Capital Reorganization Unedited CRA Tags none DATE MAR. 17, 1990 TO FROM A R.D. Snider DE Specialty Rulings Section Chief Directorate Advanced Audit & Investigations S. ...

7 December 1991 Income Tax Severed Letter- Capital cost allowance — computer equipment and software Unedited CRA Tags Reg. ... " In addition to the use of the word ancillary, subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...