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27 June 1994 External T.I. 9410195- LARGE CORPORATION TAX & CONDITIONAL SALES CONTRACTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Where a party (other than a financial institution) acquires a note issued by the purchaser under a conditional sales agreement, the note will be included in the party's investment allowance. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Brief discussion of application of s. 216 election where there is a non-resident partner in a partnership receiving rents from a MURB property. ...

3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Because an Alberta royalty tax credit is not included in a corporation's income for tax purposes, it also is not included in its safe income or safe income on hand. ...

7 September 1994 External T.I. 9415545- UNCLAIMED INTEREST & DIVIDENDS-- summary under Subsection 153(4) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(4) The reference to a "taxation year" and "year" in the preamble to s. 153(4) refers to the taxation year of the broker/security dealer and not to that of the unidentified individual (namely, a calendar year). ...

8 September 1994 Internal T.I. 9420937- HUSBAND & WIFE PARTNERSHIP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Before discussing the case law in the context of a dispute, RC stated that "in general, an acceptable partnership requires an investment by each partner, a written partnership agreement and proper notices to creditors and financial institutions concerning the existence of a partnership". ...

13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Discussion of the application of Part I.3 to loans to and from corporate partnerships, loans between partnerships and the impact of equity-based accounting for partnership interests. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) An RRSP that writes naked call options would be considered to be carrying on a business. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(9) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(9) It is the Departmental practice not to apply the provisions of s. 146(9) to an annuitant where an RRSP has written a covered call option and the holder of the covered call option in fact exercises her right to purchase under the option. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) Index options are not qualified investments for an RRSP except in respect of the particular time, if any, when it can be clearly established that cash will be realized if the options are exercised at that time. ...

10 March 1995 External T.I. 9500835- QUALIFIED INVESTMENTS & FOREIGN PROPERTY-- summary under Paragraph 206(1)(h) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1)(h) Canadian government bonds denominated in a foreign currency are not foreign property. ...