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Principal Issues: Follow-up to our letters in files 7-964086 & 5-970419. ...

The conditions in paragraph 12(1)(x) are not met. 981718 XXXXXXXXXX Allan Nelson (613) 957-9768 Attention: XXXXXXXXXX July 9, 1998 Dear Sirs: Re: Canadian film or video production tax credit This is in reply to our telephone conversations (Nelson/XXXXXXXXXX on June 23 & 25, 1998 and XXXXXXXXXX/Nelson on July 2, 1998) and your letter dated July 2, 1998, wherein you requested our opinions concerning the application of section 125.4 and paragraph 12(1)(x) of the Income Tax Act (Canada) (the “Act”). ...

Principal Issues: Principal residence- land in excess of 1/2 hectare Position: law generally explained since all facts not available Reasons: See files # 950960, 931679, 9703685, 9431495, 9502557, 9504376, 9725785. ...

On XXXXXXXXXX, the taxpayer purchased the “XXXXXXXXXX ” property which consisted of 320 acres of land and a house. 6. ...

Reasons: See Rulings file # 971711, 951676, 930195, 961018, 910602 XXXXXXXXXX 982792 G. ...

We are assuming that under the terms and conditions of the Policy the Policyholder would be allocated an additional 25 notional units in this case (25 @ $8/unit= $200). ...

The reference in 73(3) to "... eligible capital property in respect of a business carried on in Canada by a taxpayer... ...

Yours truly, Kimberley Wharram Acting Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 For the present purposes, the word “primarily” means more than 50%. 2 C.R.C. c. 945, as amended. 3 R.S.C. 1985, c. 1 (5th suppl.) as amended. 4 The following property only qualifies for an inclusion in Class 43.1: (i) mid-efficiency, fully or partially fossil-fuelled cogeneration systems; (ii) electric vehicle charging stations set up to supply more than 10 kW but less than 90 kW of continuous power; and (iii) electrical energy storage equipment connected to one of the above systems and stand-alone electrical energy storage systems meeting particular efficiency requirements. 5 See paragraphs (b) and (e) of Class 43.1. 6 See paragraphs (a) to (c) of Class 43.1 of Schedule II of the Regulations. 7 See generally, Tenneco Canada Inc. v The Queen, 91 D.T.C. 5207 (F.C.A.) and more recently, Canada v. ...

La société a calculé que les coûts d'entretien seraient d'environ XXXXXXXXXX $. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...