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13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3 Unedited CRA Tags 181.2(3)(g) 181.2(4)(e) 181.2(4)(d.1) 181.2(5) 181.2(3)(c) 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. ... Reasons FOR POSITION TAKEN: (1)-(3) LEGISLATION, (4) PREVIOUS RULING POSITIONS & 1991 CDN.TAX CONF. ...

OF 115(1)(B) & 116 WHERE A NON-RES. GRANTS AN OPTION Unedited CRA Tags 115(1)(b) 116 115(3) 115(1)(b)(i) 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. ... This interpretation is consistent with our interpretation of the expression " d'un droit y afférent" in the French version. 5-940767 XXXXXXXXXX Carole Pronovost (613) 957-8953 Attention: XXXXXXXXXX November 1, 2018 Dear Sirs: Re: Interpretation of paragraph 115(1)(b) and section 116 where a non-resident corporation grants an option to buy Canadian real property to a Canadian corporation We are writing in reply to your request of March 16, 1994, regarding our interpretation of paragraph 115(1)(b) and section 116 where a non-resident corporation grants an option to buy Canadian real property to a Canadian corporation. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS Unedited CRA Tags REG 4900(1)(e) 146(4) 204(e)(i) 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. ... Yours truly, for Director Financial Industries Division Rulings Directorate Policy & Legislation Branch ...

8 May 1996 Internal T.I. 9608607- LOAN FOR RENOVATIONS NOT EXEMPT & BONA FIDE REPAYMENTS Unedited CRA Tags 15(2.4) 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. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

19 July 1996 External T.I. 9623625- PATRONAGE ALLOCATIONS / DIVIDENDS Unedited CRA Tags 135(7) 125(1) 125.1 20(1)(v.1) 1204R 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. ... " In another speech given at the same tax conference (reproduced at pages 18 and 19 of the aforementioned book) Mr. ...

19 November 1996 External T.I. 9737005- INVESTMENT MANAGEMENT FEES OF RRSP & RRIF Unedited CRA Tags 20(1)(bb) 146(1) 146.3(2)(f) 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. ... Principal Issues: RRSP & RRIF investment management fees Position: Confirming and elaborating on our standard position that investment management fees paid by annuitant are considered payment of a premium to RRSP to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

2 December 1996 External T.I. 9621265- ALTERNATE & SPARE PARTS. Unedited CRA Tags CLASS 34 CLASS 43.1 18(1)(A) 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. ... Principal Issues: Whether alternate and spare parts could be included in Class 34 & 43.1? ...

17 December 1996 Internal T.I. 9633196- AMT ADJ RQRD IN A LOSS YR & YR OF APPLIC OF THAT LOSS Unedited CRA Tags 127.52 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. ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch c.c. ...

5 May 1995 External T.I. 9430895- CHILD CARE EXPENSE FOR UI RELATED BUSIN & EMPL INCOME Unedited CRA Tags 63(2) 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. ... Principal Issues: whether UI benefits received in conjuction with the self employment assistance program or the Unemployment Insurance Job Creation Program-section 25 qualify as earned income for purposes of the child care expense limitation Position TAKEN: no Reasons FOR POSITION TAKEN: the amounts received are benefits under the UI Act & are not in connection with the cost of a course or program designed to facilite re-entry into the labour force Youth Programs and Services Human Resources and Development Canada 4th Floor, Place du Portage, Phase IV 140 Promenade du Portage A. ...

29 June 1995 External T.I. 9505455- FLEX PLANS & CONVERSION OF SALARY TO CREDITS Unedited CRA Tags 5 56(2) 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. ... Principal Issues: 1. conversion of salary & other taxable amounts to flex credits 2. cash out of credits to a health spending account Position TAKEN: 1. taxable at the time of conversion under 56(2) and 5(1) 2. cash out provision disqualifies a health spending account as a phsp Reasons FOR POSITION TAKEN: 1. ...