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Dath Director Business & General Division Rulings Directorate Policy and Legislation Branch ...

With a view to assisting the Indian community, the Department has developed " Indian Act Exemption for Employment Income Guidelines" (the "Guidelines"), that describe the employment situations covered by the Indian Act. ...

Kerr Attention: XXXXXXXXXX December 30, 1994 Dear Sirs: This is in response to your letter of November 23, 1994, wherein you requested our views on whether the status Indian employees of your client would be exempt from income tax under the " Indian Act Exemption for Employment Income Guidelines" issued by the Department on June 29, 1994. ...

With a view to assisting the Indian community, the Department has developed " Indian Act Exemption for Employment Income Guidelines" (the "Guidelines"), that describe the employment situations covered by the Indian Act. ...

25 March 1996 External T.I. 9608875 F- APPLICATION DES ALINÉAS 80(2)G) ET (G.1) Unedited CRA Tags 80(2)(g) & (g.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

When the transferred property is cash, which is in turn used for investment purposes or to purchase other property (" substituted property"), any income or loss realized from such property, and any capital gain or loss from the disposition of the transferred property (or substituted property), is deemed to be the income or loss, or the capital gain or loss, of the individual transferor and not of his or her spouse. ...

Example B 1.A Canadian-incorporated and resident company (Canco 1) owns 100% and 65 % of two other Canadian-incorporated and resident companies (Canco 2 and Canco 3 respectively). 2.Canco 2 owns 100% of a foreign holding company (Forhold 2), and Canco 3 owns 100% of a separate foreign holding company (Forhold 3). 3.Forhold 2 has an interest of 10% in a partnership (P1), and Canco 3 and Forhold 3 have interests of 65% and 25% respectively in P1. 4.P1's only assets are 25% of the share capital of a foreign operating company (Forco) and a 90% interest in a second partnership (P2). 5.Forco and P2 carry on active business operations exclusively outside Canada, and all or substantially all of the property of Forco and of P2 are used or held principally for the purpose of gaining or producing income form their active businesses. ...

Subsection 4900(4) of the income Tax Regulations (the " Regulations") provides that a mortgage secured by real property situated in Canada is a qualified investment of an RRSP unless the mortgagor is the annuitant under the plan or is a person with whom the annuitant does not deal at arms length. ...

Yours truly, for Director Resources, Partnerships & Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Our comments Paragraph 6 of Interpretation Bulletin IT-433R sets out the Department's position with respect to a post-dated cheque accepted in absolute payment of a debt and reads, in part, as follows: "... where a post-dated cheque is accepted in absolute payment of debt, the value of the post-dated cheque is normally considered to be income at the time it is received subject to a subsequent adjustment if it is not honoured on subsequent presentation for payment. ...