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8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) "The filing of a return of income pursuant to section 216 cannot have any impact on whether or not an individual meets the 'all or substantially all' test in section 118.94. ...

24 March 1994 External T.I. 9335755- RRIF PAID TO UK RESIDENT- PENSION & ANNUITY (U4-100-17)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Notwithstanding the definition for "annuity" found in s. 5 of the Income Tax Conventions Interpretation Act, a payment out of a RRIF which qualifies as a "periodic pension payment" under the ITCIA which is paid to a resident of the UK, falls under the term "pension" in paragraph 3 of Article XVII of the UK Convention. ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) A terminal loss in the year of change from exempt to taxable status is deductible. ...

6 June 1994 External T.I. 9337485- Partie XIII — Droit d'utilisation de logiciels information-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) The position of Revenue Canada that a payment for the use of, or the right to use, software in Canada is caught by s. 212(1)(d)(vi) applies even if the payment is made as a lump sum rather than periodically. ...

30 September 1994 Internal T.I. 9414527- BORROWINGS & EXCESS INSURANCE COLLATERAL-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Where the life insurance coverage under an assigned policy is $500,000 and the average balance owing under the borrowing is $200,000, the amount deductible under s. 20(1)(e.2) is limited to 40% of the lesser of the premiums payable and the net cost of pure insurance under the policy for the year. ...

23 July 1996 External T.I. 9612365- ARTICLE XI(4) & "INCOME ASSIMILATED TO INCOME"...-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 A payment by a credit union to a member, in respect of a share of capital stock, which is deemed to be interest by s. 137(4.1) of the Act will be considered to be interest for purposes of Article XII of the Canada-U.S. ...

23 November 1993 External T.I. 9322405 F- SR & ED-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Where a non-resident company makes charges in the form of technical fees, royalties or licence fees to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of SR&ED previously performed in Canada, this will not jeopardize the eligibility of the Canadian taxpayer for the ITC. ...

27 March 1994 Income Tax Severed Letter 9508671- LIFETIME CAPITAL GAINS EXEMPTION & PERSONAL TRUST-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) Because it is not possible for a deemed capital gain (in this instance, arising under s. 110.6(19)) to be income (or a capital gain) for trust purposes, a capital encroachment power and/or the issue of a promissory note would not be sufficient to make such a deemed gain payable for purposes of s. 104(24). ...

26 July 1995 External T.I. 9501585- court ordered partition & sale disposition-- summary under Subsection 44(1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1) Where as a result of the bankruptcy of one of the four co-tenants of rental properties, a court-appointed trustee receives court approval for severance, partition and sale of the property, the non-bankrupt co-tenants would be entitled to utilize s. 44(1) in respect of their proceeds (in this case, property interests in other co-owned buildings). ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) "For purposes of Part I.3, and with respect to leases, it is the department's position that it is the legal nature of the agreement that governs irrespective of the accounting treatment or nomenclature used to describe or characterize the related transaction(s). ...