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3 February 1988 Income Tax Severed Letter 5-5287- [] XXXX R. Nanner (613) 957-3494 February 3, 1988 Dear Sir: We are writing in reply to your letter of December 16, 1987 concerning transferability of a commuted registered retirement savings plan (RRSP) annuity to a registered retirement income fund (RRIF) pursuant to subsection 146(16) of the Income Tax Act (the "Act"). ...

24 March 1986 Income Tax Severed Letter 5-1210- [] XXXX (A-2052) C. Kauppinen (613) 995-0051 March 24, 1986 Dear XXXX This is in reply to your letter dated March 3, 1986 which is further to our letter of February 18, 1986 regarding the potential application of paragraph 204.2(1)(b) in a situation in which an annuitant of a self-directed RRSP directs XXXX as trustee of the plan, to invest in a mortgage where the annuitant under the plan is the mortgagor. ...

20 May 1986 Income Tax Severed Letter 5-1325- [] Mr. G.E.. Racine Chief Advisory Services Pay Products Group Accounting, Banking and Compensation Directorate Supply and Services Canada Ottawa, Ontario K1A OS5 G.D. ...

7 May 2024 CALU Roundtable Q. 8, 2024-1007121C6- IPPs & Past Service Contributions Unedited CRA Tags ITR 8303(6) Principal Issues: Whether a transfer of property from a RRIF to an IPP is a qualifying transfer for purposes of subsection 8303(6) of the Regulations? ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease CRA Tags 66(15) "Canadian resource property" 66.4 Principal Issues: How is an amount received for granting a lease of rights to explore for, drill for or extract petroleum, natural gas or other hydrocarbons reported for income tax purposes? ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

22 October 2013 External T.I. 2013-0503311E5- Class. of steel tanks & oak barrel for CCA purpose CRA Tags 125.1(3) "manufacturing or processing" ITR 1109 "manufacturing or processing" ITR Schedule II- Class 8 ITR Schedule II- Class 29 ITR Schedule II- Class 43 Principal Issues: Whether steel tanks and oak barrels used for fermenting/clarifying/blending and/or aging wine, and acquired after March 18, 2007 and before 2016, would be included in class 29 of Schedule II of the Income Tax Regulations. ... For further discussion in this regard, see IT-147R3, "Capital Cost Allowance – Accelerated Write-Off of Manufacturing and Processing Machinery and Equipment", which is available on the CRA's website. ...

12 June 2012 Roundtable, 2012-0442941C6- STEP Roundtable – June 2012- Question 4 CRA Tags 70(1) Principal Issues: (a) Whether subsection 70(1) is limited to the types of income specified therein, or does it apply generally to all items of income payable on a periodic basis? ... STEP CRA Roundtable – June 2012 QUESTION 4 Subsection 70(1) provides a rule whereby in the year of death certain sources of income are to be determined on an accrual basis. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves CRA Tags 110.6(1) 110.6(2) 66.4(5) 66(15) 110.6(1.3) 248 Principal Issues: Whether the taxpayer's farm would continue to meet the definition as a "qualified farm property", if oil reserves are discovered on the property. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

10 June 2015 External T.I. 2015-0580531E5- joint account & estate returns CRA Tags 104(13) 70(5) Principal Issues: TREATMENT OF PROPERTY HELD IN JOINT OWNERSHIP AT DEATH Position: LEGAL DETERMINATION REQUIRED Reasons: TAX TREATMENT DEPENDS ON LEGAL & BENEFICIAL OWNERSHIP OF THE PROPERTY. ...

16 November 2015 External T.I. 2015-0595471E5- Partnerships & capital gains reserve CRA Tags 96(1) 40(1) Principal Issues: Is a capital gains reserve under subparagraph 40(1)(a)(iii) claimed at the partner or partnership level? ... Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...