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

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

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. ...

Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ANGIND E DOCNUM 9401365 REPLACES TYPEKEY R AUTHORDV LEGS AUTHOR CCHOUI DESCKEY 5 RATEKEY 1 REFDATE 940722 ETADYEAR ETADSORT ADMINACC LEGS ACCESSLV LEGS99 SUBJECT Non-qualifying real property SECTION ITA-110.6(1) SECTION SECTION SECTION SECTION $$$$ 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. ...

Les intérêts sur l'emprunt déductibles totalisent XXXXXXXXXX $, soit la proportion des intérêts réclamés par le rapport entre la somme du capital versé des actions rachetées et des bénéfices non répartis et le montant payé pour le rachat des actions. 11. ...

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

The Court did, however, also specify that "This does not necessarily mean that the physical location of the Crown is irrelevant to the purposes underlying the exemption from taxation provided by the Indian Act ". ...

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

LAW: An "employee benefit plan" is defined in subsection 248(1) and the words which are relevant to the Plan described above are as follows: An arrangement under which contributions are made by an employer... to another person with whom the employer does not deal at arm's length (... the "custodian" of an employee benefit plan) and under which one or more payments are to be made to or for the benefit of employees or former employees of the employer or persons who do not deal at arm's length with any such employee or former employee. ...

Principal Issues:taxation of an out of court settlement pertaining to discrimination based on sex Position TAKEN:-settlement allocation unreasonable based on reported awards under the Ontario Human Rights Tribunals-amount for lost wages employment income-a reasonable amount for mental anguish & loss of dignity would be tax exempt-reimbursement of legal fees not taxable Reasons FOR POSITION TAKEN: the lost wages are not for loss of employment since she resigned voluntarily February 9, 1995 TORONTO CENTRE TAX SERVICES Rulings Directorate Source Deductions Division A. ...