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For instance it has already been determined that the exemption will apply to:-     employment income for duties performed entirely on a reserve;-     employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve;-     employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and,-     unemployment, pension and retiring benefits received in respect of exempt employment income. ...

For instance it has already been determined that the exemption will apply to: • employment income for duties performed entirely on a reserve; • employment income for duties performed entirely off a reserve where the employer resides on a reserve and the Indian lives on the reserve; • employment income for duties, a substantial amount of which are performed on a reserve and either the employer is located on the reserve, or the Indian lives on the reserve; and, • unemployment, pension and retiring benefits received in respect of exempt employment income. ...

. • as required by B.C. law, individual parcels may not exceed 520 hectares (approx. 1285 acres); • these consist of arable/non-arable plots containing stated quantities of merchantable timber as established by Ministry timber cruises; • their location, means of accessing, the type of soil and topography, the services available, if any; • the amount spent by the Ministry to date on the parcels' development; and • the amount of the purchase price should the option to purchase be exercised. 4. ... In terms of timber administration on the leased crown agricultural lands, the following relevant information is noted: • as stated above, a license to cut timber is granted to the lessee; • stumpage rates are determined by current timber pricing policies; • as regards to "arable" lands (lands fit for ploughing and growing crops), the Ministry seeks timely cultivation and thus issues a license to cut a maximum of 80 arable acres at a time, and will not issue a license to cut the next 80 acres until at least 25% of the first is cultivated. ... The provision applies where "... a taxpayer has acquired a particular property in respect of which, immediately before that time, he had a leasehold interest that was included in a prescribed class... ...

19 February 1988 Income Tax Severed Letter February 19, 1988 SURREY TAXATION CENTRE HEAD OFFICE- APPEALS BRANCH Appeals & Referrals Division P. ... Section Chief Appeals & Referrals Division PB/ltb Encl. c.c. (1) section 62(3) research files (2) J. Rutherford Assessing & Enquiries Directorate ...

In your letter you outlined the following hypothetical situation: • A holding corporation ("Holdco") was incorporated in British Columbia in January 1987. • 100% of the issued shares of Holdco are owned by a Canadian personal trust, the beneficiary of which is resident individual. • Holdco is assumed to be a Canadian controlled private corporation as defined in subsection 125(7) of the Act. • In February 1987, Holdco entered into a Limited Partnership agreement. ... In addition, Holdco contributed a $400,000 loan to the partnership at prime + 1% to be repaid over five years by blended payments of principal and interest. ... The loan has the same terms as the loan made by Holdco to the partnership. • The partnership has been engaged in an active business since February 1987. ...

In your letter you outlined the following hypothetical situation: • A holding corporation ("Holdco") was incorporated in British Columbia in January 1987. • 100% of the issued shares of Holdco are owned by a Canadian personal trust, the beneficiary of which is a resident individual. • Holdco is assumed to be a Canadian controlled private corporation as defined in subsection 125(7) of the Act. • In February 1987, Holdco entered into a Limited Partnership agreement. ... In addition, Holdco contributed a $400,000 loan to the partnership at prime + 1% to be repaid over five years by blended payments of principal and interest. ... The loan has the same terms as the loan made by Holdco to the partnership. • The partnership has been engaged in an active business since February 1987. ...

It is your view that the tax implications to the employee and corporation would be as follows: Impact to Employee • Gain on sale of options- $7 per share • Paragraph 7(1)(c) of the Income Tax Act (the "Act") benefit- $7 per share Impact to Corporation • Selling price of shares equal to the adjusted cost base of the shares to the corporation In our view, the non-arm's length transfer of the stock option does not give rise to a tax liability to the transferor at tie time of the transfer in the above situation. ...

The income of the partnership was $ 1O million of which USCO's share was $ 5 million. 6. The only assets of the partnership now consist of mortgages receivable having a fair market value of $ 14.6 million, 7. ... (Refer to exhibit 3) • The Canadian shareholder (individual or corporation) of a controlled foreign affiliate is taxed on its pro rata share of the affiliate's FAPI for the year on the accrual basis. ...

You have requested that we provide our comments as to whether the taxpayer, in the situations described below, would be considered to derive all or substantially all of his revenue from the prosecution of or sale of rights in or arising out of SR & ED. ... Should the taxpayer derive his revenue in the manner described in examples 3 and 4 above, it is our view that the income would generally be considered to have been derived from the prosecution of SR & ED. ... Accordingly, this revenue would not be considered to have been derived from the prosecution of or sale of rights in or arising out of SR & ED. ...

It is our view, based on the principle adopted in the West Kootenay Power & Light Company Limited v. the Queen 92 DTC 6023 and Maritime Telephone & Telegraph Company, Limited v. the Queen 92 DTC 6191, that the business interruption insurance proceeds may be reported on the accrual basis for income tax purposes provided that there is no alternative method which presents a "truer picture" of the taxpayer's revenue. ...