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25 July 1990 Ministerial Letter 901148 F- Interest Income Unedited CRA Tags n/a 24(1) 901148   C.R. ... Facts Our understanding of the facts given to illustrate the issue is as follows:      A consumer signs an order to make a purchase of goods from a Canadian manufacturer/retailer and pays a cash deposit which is not refundable after 30 days.  ... 2)     Are manufacturers' rebates, such 85 those offered by auto and appliance retailers, required to be included in the income of the purchaser of such products? ...

14 June 1990 Ministerial Letter 59848 F- General Anti-avoidance Rule- Requirement of Misuse or Abuse Unedited CRA Tags 245(4) 24(1) File No. 5-9848   M. ... Wilson, Minister of Finance in June 1988:      "Cet article fait mention d'un abus en égard aux dispositions de la Loi, lue son ensemble, aussi bien qu'à certaines dispositions précises. ...

The hypothetical situation outlined in your letter was as follows: 1)     Company A carried out scientific research and experimental development ("SR & ED") with a view to creating a product which is unrelated to its existing business. 2)     Mr. B, an unrelated party, wished to participate in the SR & ED project.  ... B contributed cash. 3)     The partnership continues to carry out SR & ED.  ...

3 July 1992 Ministerial Letter 9218428 F- Deductibility Of Mortgage Interest Unedited CRA Tags 18(1)(a), 20(1)(c)   921842   L. Holloway   (957-2131) June 30, 1992 Minister/DM's Office                       YS 92-4865TCentral RecordsAuthor/Section ChiefDistrict OfficeResearch FileTaxpayer's FileReturn to Rulings Directorate, Room 303, Met. signed by Pierre Gravelle on July 3, 1992 19(1) Dear 19(1) I am writing in response to your letter of May 15, 1992, which was forwarded by The Honourable Don Mazankowski, concerning the deductibility of mortgage interest costs incurred in financing your personal residence. ...

16 July 1990 Ministerial Letter 900348 F- Advance Payment of Death Benefits to Terminally Ill Policyholders Unedited CRA Tags 148(9) disposition, 148(9) life insurance policy 19(1) 900348   M.M. Trotier   957-8957   EACC9432 July 16, 1990 19(1) This is in reply to your letter of April 4, 1990 concerning the taxation of the advance payment of death benefits to policyholders suffering from terminal illnesses.  ...

16 November 1989 Ministerial Letter 74238 F- Child Tax Credit and Computation of Family Net Income Unedited CRA Tags 122.2, 122.4   November 16, 1989 Non-Resident Taxation Division Specialty Rulings K. ... Your concern arises because of the following statement contained in Information Circular 80-3R2 (cancelled in December, 1986) at paragraph 17:      "A spouse is still considered to have resided with the claimant, at December 31, if separated only for business, employment, medical or educational reasons. ... In this regard we refer you to the following comments contained in Interpretation Bulletin IT-221R2 at paragraphs 4 and 8: Paragraph 4  "Where a Canadian resident is absent from Canada (for whatever      reason) for less than 2 years, he will be presumed to have retained his residence status while all residential ties on leaving Canada. ...

5 November 1992 Ministerial Letter 9118508 F- Damages Awards as Retiring Allowances Unedited CRA Tags 248(1) Damages, 248(1) Retiring allowance Personal and General Section      Jack SzeszyckiNovember 5, 1992 The issue is whether general damages received by an employee for loss of self respect, mental anguish, humiliation or hurt feelings falls within the parameters of the word "damages" contained in the definition of retiring allowance under subsection 248(1) of the Act and therefore taxable under subparagraph 56(1)(a)(ii) of the Act. ...

Yours sincerely, Pierre Gravelle, Q.C. c.c.      Carole Gouin Toussaint M93-3845T ...

DathDirectorBusiness and General DivisionRulings Directorate cc.      ...

3 April 1990 Ministerial Letter 59778 F- Transfer of RRSP Funds on Death of Annuitant Unedited CRA Tags 146(8.1), 60(1), 146(8.9), 146(8.8), 152(4) 19(1) File No. 5-9778   D.S. Delorey   (613) 957-3495 April 3, 1990 Dear Sirs: This is in reply to your letter of March 12, 1990 concerning the transfer of registered retirement savings plan ("RRSP") funds on the death of the annuitant. ... Of particular relevance to your situation are the following comments contained in paragraph 19:      "Where a refund out of a depositary plan is paid after the death of the annuitant, Interest or income eventually paid that accrued after the date of death will be included in the income of the person entitled to the deposit (i.e., the estate of the deceased annuitant or the beneficiaries) and will not qualify as a refund of premiums. ...