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We have discussed this matter with Finance, however, should you wish to pursue this matter we would suggest that you write to Finance at the following address: Tax Policy & Legislation Branch Department of Finance 140 O'Connor Street L'Esplanade Laurier 17th Floor, East Tower Ottawa, Ontario K1A 0G5 With respect to an employee, if a taxpayer was in receipt of income from an office or employment that included income from an artistic activity that was the composition by the taxpayer of a literary work, then in computing the taxpayers income for a taxation year from an office or employment the taxpayer may be able to deduct amounts paid by the taxpayer before the end of the year in respect of expenses incurred for the purpose of earning the income from that activity to the extent of the amount determined under paragraph 8(1)(q) of the Act. ...

26 August 1993 External T.I. 9321085 F- Trust or Agency Unedited CRA Tags 104(1), 150(1)(c), 150(3)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Preparation of a T3 or a T5 Return This is in reply to your letter of July 13, 1993 concerning the concepts of trust versus agency relative to whether a T3 or a T5 return is required to be prepared for a client, and the consequences of any "assessment proceedings. ...

18 October 1993 External T.I. 9323355 F- Provision of Services and Information (T2 File) Unedited CRA Tags 212(1)(d)(ii), 212(1)(d)(iii)   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 212(1)(d) of the Income Tax Act (the "Act") This is in reply to your letter of August 11, 1993 wherein you requested our opinion concerning the following situation. ...

(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",... ...

Albert for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch Encl. c.c.      ...

RULINGS DIRECTORATE CORRESPONDENCE SUMMARY DOCUMENT TYPE:Opinion FILE # E9400085 Principal Issues: Is termination pay in lieu of notice a retiring allowance? ...

The definition of "qualified small business corporation share" in subsection 110.6(1) of the Act reads, in part, as follows: "... more than 50% of the fair market value of the assets of which was attributable to (a)assets used principally in an active business... ...

Yours truly, for Director Financial Industries Division Rulings Directorate Policy & Legislation Branch ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretation Directorate Policy & Legislation Branch ...