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For further information, we suggest that you consult our Interpretation Bulletin IT-110R3 and our pamphlet titled "Registered Charities and the Income Tax Act " (RC 4108), both of which are available on the internet through our website at http:\ www.ccra-adrc.gc.ca. ...

Position: Likely yes Reasons: If RPP member's employment income was tax-exempt, and the beneficiary is a status Indian, the Guidelines exempt both principal & investment income from taxation. 2002-015948 XXXXXXXXXX R. ...

You say that based on the Canada Customs & Revenue Agency's (the "CCRA's") inadvertence, it requested and obtained a payment of CAN$20 under paragraph 116(4)(a) based on the computation of the gain being CAN$80, rather than US$80. ...

Reasons: If RRIF funds originated as an RPP entitlement related to tax-exempt employment income, the Guidelines exempt both principal & investment income paid to a status Indian from taxation. 2002-017002 XXXXXXXXXX Renée Shields (613) 948-5273 November 12, 2002 Dear XXXXXXXXXX: Re: Tax Exempt Status of RRIF Payments This is in response to your facsimile of October 14, 2002 addressed to the Toronto Centre Tax Services Office inquiring about whether registered retirement income fund (RRIF) payments to a status Indian are tax-exempt. ...

However, generally speaking, in situations where a controlling shareholder / director of a particular corporation approves a transfer or loan of property by the particular corporation to another corporation and the property transferred or loaned may be considered to come from the particular corporation's retained earnings (for example, internally generated cash or investments of the particular corporation) such that the property would not represent property paid or transferred to the particular corporation, directly or indirectly, by the individual, it is our view that the transfer or loan of property to the other corporation would not be considered to have been made, indirectly, by the individual for the purposes of subsection 74.4(2) of the Act. ...

Gifts by Direct Designation This is in reply to your letter dated January 30, 2002, which was forwarded to us from the Charities Directorate, and our subsequent telephone conversations (Cooper & Workman/XXXXXXXXXX) in which you requested our comments with respect to the interpretation of the definition of "disbursement quota" (the "DQ") in subsection 149.1(1) of the Income Tax Act (the "Act") in particular circumstances. ...

Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

In the second test, the expenses must meet the preamble to subsection 20(1) which is, "... there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may be regarded as applicable thereto... ...

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

In the context of whether income from property qualifies for the small business deduction, paragraph 6 of Interpretation Bulletin IT-73R5 entitled The Small Business Deduction states, ".... ...