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29 March 1993 External T.I. 9235745 F- Definition of Active Business Income Royalty Income Unedited CRA Tags 110.6(1) qualified farm property   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Definition of Active Business Income This is in reply to your letter dated November 26, 1992 requesting an interpretation of whether royalty income earned by a farming operation would be considered to be active business income. ...

14 April 1993 External T.I. 9300305 F- Allowable Business Investment Loss- Capital Losses Unedited CRA Tags 39(1)(c), 50(1)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 39(1)(c) of the Income Tax Act (the "Act") This is in reply to your letter of January 4, 1993 requesting a technical interpretation on the application of paragraph 39(1)(c) to a particular fact situation. ...

15 April 1993 External T.I. 9237445- Mandataire Unedited CRA Tags 9   5-923744 XXXXXXXXXX A. ...

26 April 1993 External T.I. 9235535 F- Lien Notes and Large Corporations Tax Unedited CRA Tags 181.2(3)(d), 181.2(3)(f)   XXXXXXXXXX Attention:  XXXXXXXXX Dear Sirs: RE:  Large Corporations Tax and Lien Notes of Automobile Dealerships This is in reply to your letter of November 24, 1992 on the above noted topic. ...

Our Comments: Paragraph 4 of Interpretation Bulletin IT-431R2, entitled `Order of provisions applicable in computing taxable income of an individual' with respect to losses, states: 4.      ...

21 June 1993 External T.I. 9302205 F- Date of Acquisition For Transferred Prop Re 110.6 Limit Unedited CRA Tags 110.6(18)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Capital Gains Exemption on Real Estate disposed of after February 1992 We are replying to your letter of January 20, 1993 concerning the effect of a transfer of property between spouses on the transferee's ability to claim a capital gains exemption on any subsequent disposition thereof. ...

8 December 1992 External T.I. 922739A F- Qualified Small Business Corporation Share Unedited CRA Tags 110.6(1) qualified small business corporation share (c), 110.6(1) qualified small business corporation share (d)   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 110.6(1)(d) of the Income Tax Act (the Act) This is in reply to your letter dated September 15, 1992, requesting that we reexamine a previous interpretation obtained from our office regarding the definition of qualified small business corporation share for purposes of the capital gains deduction. ...

Unedited CRA Tags 126   XXXXXXXXXX Dear Sir: This is in reply to your inquiry made to the Public Affairs Office of the Ottawa District Office concerning the rationale behind paragraph 4 of Interpretation Bulletin 372R (IT-372R). ...

(c)     qualified property of the taxpayer if the definition "qualified property" were read without reference to paragraphs (a) and (d) of it and if the reference to "after June 23, 1975" were read as a reference to "after December 2, 1992 and before 1994",... ...

21 July 1993 External T.I. 9316625 F- RRSP Qualified Investments, Bonds Stripped Bonds Unedited CRA Tags 20(14)(a), 54 capital property   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sir: RE:  Canada Savings Bonds, Stripped Bonds and GICs held by Registered Retirement Savings Plans This is in reply to your facsimile transmission dated May 16 1993, addressed to the Audit Division of Revenue Canada and referred to us for reply. ...