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Dodd (613) 957-8954 April 18, 2001 Dear XXXXXXXXXX: Re: Allocation of Partnership Income Between Provinces Our Letter dated November 17, 2000 (File # 2000-005481) We are writing further to our November 17, 2000 reply to your letter dated October 30, 2000 concerning section 402 of the Income Tax Regulations (the "Regulations"). ...

One of the requirements, in paragraph 118.3(1)(c) of the Act, provides that the credit is only available if: " (c) no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than because of paragraph 118.2(2)(b.1)) for the year by the individual or by any other person," The payments that are described in paragraph 118.2(2)(b.1) of the Act (which do not prevent a disability tax credit claim) are, in general terms, only amounts that are paid as remuneration for "attendant care". ...

" Reasons: The definition of pension income provided under subsection 118(7) of the Act / Previous opinion. ...

October 24, 2001 Brian Whittingham HEADQUARTERS Verification & Enforcement Cornelis Rystenbil, CGA Vancouver Island Tax Services (613) 941-6547 2001-009908 Paragraph 149(1)(d) of the Income Tax Act (the "Act") This is in reply to your correspondence of August 30, 2001, and our telephone conversations (Whittingham/Azzi) in which you ask for our view on the application of paragraph 149(1)(d) of the Act for the taxation years ending in 1995 to 1998 of corporations owned by an Indian band which, as a result of the Otineka Development Corporation Limited (94 DTC 1234) case, qualifies as a municipality for purposes of paragraph 149(1)(c) of the Act. ...

In this regard, we would like to point out that our position with regard to the source of interest expenses incurred by a partner of a partnership for the acquisition of an interest in the partnership as expressed in document #9716025, dated July 14, 1997, has been superseded by that stated in document # 2000-0020335, dated June 15, 2000. ...

However, as indicated in paragraph 1 of Interpretation Bulletin IT-387R2, Meaning of "Identical Properties", it is our view that " 'Identical properties...are properties which are the same in all material respects, so that a prospective buyer would not have a preference for one as opposed to another. ...

Abramchuk: Re: Net Income Stabilization Account (NISA) This is in reply to your letter of September 5, 2001, requesting further clarification of our opinion letter 5-991169 regarding the tax implications of changes to Deposit / Withdrawal options. ...

With regard to paragraphs 14(3)(b), (b.1) and (b.2) of the Act, they refer to "... amounts that can reasonably be considered to have been claimed as deductions under section 110.6... in respect of the disposition... ...

In your letter you refer to a published CCRA document (# 1999-0011055) that confirms that our long-standing policy allowing the use of a single purpose corporation to acquire certain U.S. real estate is still in effect as long as the seven conditions as outlined therein continue to be met (see also Q. 6.4 of the Congrès 1998 de l'Association de planification fiscale et financière). ...

Paragraph 1 of IT-385R2 provides that "Income of a personal trust [...] means income computed for trust accounting purposes and not for income tax purposes... ...