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As noted in paragraph 3 of Interpretation Bulletin IT-460, Dispositions – Absence of Consideration, where a partnership is dissolved and the taxpayer is not entitled to and does not receive any share of the partnership's net assets (if any), the dissolution would generally result in a disposition of the partnership interest and an amount of zero may be used as proceeds of disposition for purposes of computing a loss from the disposition. ...

Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Position: None taken- some general comments regarding situation where a taxpayer carries on a business that involves farming activities (growing grapes) and non-farming activities (i.e. processing of farm product – producing wine for sale). ...

Paragraph 31 of Interpretation Bulletin IT-533 Interest Deductibility and Related Issues (which is available on the CRA website at http://www.cra-arc.gc.ca/E/pub/tp/it533/README.html) discusses borrowing for investments as follows: ¶ 31. ...

The CRA's general views regarding 149(1)(l) entities are contained in Interpretation Bulletins IT-496R, “Non-profit Organizations”, and IT-83R3, “Non-profit organizations – Taxation of income from property”, which may be viewed at http://www.cra-arc.gc.ca. ...

Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Yours truly, Robert Demeter, CGA, CPA Section Manager For Division Director International Section I Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch Encl: Objection process for Income Tax purposes ...

You reference that T4117, Income Tax Guide to the Non-Profit Organization (NPO) Information Return, states: "Line 114 – Fixed Assets Fixed assets include land, buildings, and equipment. ...

Exceptions to this general rule are structures and buildings specifically included in another CCA class, such as Class 6 – generally speaking, a building made of frame, log, stucco on frame, galvanized iron, or corrugated metal (corrugated iron before 1988) and in addition, one of the following conditions applies: you acquired the building before 1979; the building has no footings or other base supports below ground level; or the building is used to gain income from farming or fishing. ...