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27 June 1989 Income Tax Severed Letter AC57919- Corpotation Qualifying as "Non-profit Corporation" for SR & ED 57919 C.R. ... Prior to the incorporation of a non-profit corporation for scientific research and experimental development, the Department is prepared to rule on whether or not the corporation when incorporated will be "constituted exclusively for the purpose of carrying on or promoting "SR & ED" for the purpose of paragraph 149(1)(j). ... However, the Department can provide an opinion, which is not binding on the Department, as to whether, based on the assumption that the corporation does qualify under paragraph 149(1)(j) of the Act, the payments made to the corporation by contributors will be deductible under subsection 37(1) of the Act if the taxpayer carries on a business in Canada, the payments are to be used for SR & ED carried on in Canada which is related to a business of the taxpayer, and the taxpayer is entitled to exploit the results of such SR & ED. ...

All copies are then to be sent to the RRSP issuer or RRIF carrier from which the property is to be transferred (the Transferor). • Part III of all copies is to be completed and signed by the Transferor who shall keep Copy 4 and send Copies 1, 2 and 3 to the Transferee along with the funds or property being transferred. • Part IV of Copies 1, 2 and 3 is to be completed and signed by the Transferee. ... DEFINITIONS • "Individual Plan No." and "Individual Fund No. ... This includes a duly appointed agent of such a person. • "RRIF carrier" means a person described in paragraph 146.3(1)(b). ...

16 January 2008 External T.I. 2007-0260071E5- Instalment Interest & Penalties-Inter Vivos Trust Unedited CRA Tags 156 Principal Issues: Does the CRA assess instalment interest and penalties where an inter vivos trust does not make instalment payments? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc. Joffrine Mailhot, T1/T3 Returns Processing Section, Processing Division, Individual Returns & Payments Processing Directorate, Assessment and Benefit Services Branch ...

5 March 1986 Income Tax Severed Letter 6013-2- [Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures] Unedited CRA Tags 67, 245(1), 37(1), 194(2) Decision Summary Scientific Research Section Subject: Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures Reference: 67, 245(1), 37(1) and 194(2) Issue: Do 67 and 245(1) apply to 37(1)(a) and 37(1)(b) amounts claimed as a Part VIII refund under 194(2)? ... Decision: To accept the legal opinion that 67 and 245(1) apply to R & D expenditures claimed as a Part VIII refund as defined in 194(2). ...

20 October 1989 Income Tax Severed Letter AC80320- D & B Oilfield Contracting Ltd.- Adverse Decision E. ... Angus 8-0320 RE: D & B OILFIELD CONTRACTING LTD. ADVERSE DECISION- TAX COURT OF CANADA This is in reply to the memorandum of September 20, 1989. ...

19 April 1990 Income Tax Severed Letter 900259- Self-directed RRSP — Mortgage as Qualified Investment Unedited CRA Tags 146(1)(g), Reg. 4900(1)(j), 4900(4) This is in reply to your letter of March 27, 1990 concerning the above-mentioned subject. ... As outlined in paragraph 8 of Interpretation Bulletin IT-320R, (special Release dated May 25, 1984) other requirements to be met include • the amount of the mortgage interest rate and other terms must reflect normal commercial practice, and • the mortgage must be administered as if it were on property owned by a stranger. ...

7 June 1990 Income Tax Severed Letter AC74847- Oil & Gas Steering Committee Unedited CRA Tags none Special Audits Division Resource Industries E.H. ... Gauvreau 957-8953 7- 4847 Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ...

18 March 1983 Income Tax Severed Letter 5-0057- [(1) Gross & Net Royalty Trust/(2) Reporting of Resource Income and Allowances] DATE: March 18, 1983 TO- Corporate Rulings Division FROM- Audit Programs Division Estate and Trust Group T. ... Carsley RE: (1) Gross & Net Royalty Trust (2) Reporting of Resource Income and Allowances We refer to the attached memoranda at March 8 and 15 concerning resource income and resource allowance. ...

24 January 1990 Income Tax Severed Letter ACC8926- Canada-Portugal Reciprocal Air & Shipping Exemption B. Fioravanti (613) 957-2073 HBW 4290-1 19(1) January 24, 1990 Dear 19(1) Re: Canada- Portugal- Reciprocal Air & Shipping Exemption Your letter of January 9 together with enclosures has been referred to the attention of C. ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Is the income earned by a farmer for the rental of farmland to a third party who enters into FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ...