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31 May 1985 Income Tax Severed Letter RCT A-0947 F Unedited CRA Tags 107(5) Dear Sirs: RE:     Subsection 107(5)- Taxable Canadian Property This is in reply to your letter of January 8, 1985. ... You point out, the general scheme of the Act contemplates the ownership of taxable Canadian property with reference to non-residents (e.g. in paragraph 48(1)(a) of the Act which refers to "... any property... that would be taxable Canadian property if at no time in the year he had been resident in Canada... ...

24 June 1982 Income Tax Severed Letter RCT-0483 F Dear Sirs: RE:     Non-Resident Corporation Receiving Rent on Real Property in Canada This is in reply to your letter of May 3, 1982 wherein you requested our opinion as to the Canadian tax consequences in respect of the following hypothetical fact situation: 1. ... P Co has elected under subsection 216(1) of the Income Tax Act, Canada ("Act") to be taxed in respect of its Canadian source rental income on a "net " basis for its 1982 taxation year ended December 31, 1982; 6. ...

7 October 1987 Income Tax Severed Letter 95-3865 F Dear Sirs: RE:     Technical Interpretation on Meaning of "Amount Deposited" This is in reply to your letter of September 9, 1987. ... In connection with this question1 you refer to the quotation by the Supreme Court of Canada in Re Alberta Legislation, [1938] 2 D.L.R. 81 at 99, from Macleod, Theory of Credit at pp. 368-9, as follows: "... it is the entry to the credit of the customer which, in the technical language of modern banking is termed a Deposit... ... " You also provide quotations from Crawford and Falconbridge: Banking and Bills of Exchange, 8th edition, volume 1, at pp 339-340: "... all indebtedness incurred by a Canadian chartered bank for borrowed money- with the important exception of funds received from the issue of bank debentures is properly referred to as a deposit", and at p. 759, "It follows from these passages that a deposit could, depending on the contractual terms, refer to money loaned to a bank in exchange for any kind of document evidencing such indebtedness, including bonds, debentures (but not bank debentures), promissory notes and bank passbooks. ...

11 December 1987 Income Tax Severed Letter 93-1505 F Dear Sirs: RE:     XXX This is to confirm our telephone conversation of December 11, 1987 in which you advised us that the advance income tax ruling on behalf of XXX dated October 30, 1987 be withdrawn. ...

18 March 1981 Income Tax Severed Letter RCT 5-1938 F Unedited CRA Tags none Dear Sirs: RE:     Capital Dividend Account- Calculations after an amalgamation This is in reply to your letter dated October 27, 1980 concerning the calculation of a capital dividend account. ...

6 September 1984 Income Tax Severed Letter RCT 5-6456 F Unedited CRA Tags 85(1.1) Dear Sirs: RE:     Application of Subsection 85(1.1) after February 15, 1984 This is in reply to your request for our opinion on the application of subsection 85(1.1) of the Income Tax Act to the transfer of a resource property to a new corporation pursuant to subsection 85(1), followed by the wind-up of the new corporation into its parent utilizing subsection 88(1). ...

25 March 1985 Income Tax Severed Letter RCT 5-7482 F Unedited CRA Tags 148(10)(e), 89(1)(b) Dear XXX: RE:     Paragraph 148(10)(e) and 89(1)(b) In response to your letter of March 1, 1985 it is our opinion that paragraph 148(10)(e) does not apply for the purposes of paragraphs 89(1)(b) and (b.2). ...

8 September 1980 Income Tax Severed Letter RCT 5-1710 F Unedited CRA Tags 59(2), 85(1.1) Dear Sir: RE:     Rollover of Partnership Interest In your letter of August 6, 1980 you requested our opinion as to the potential applicability of subsection 85(1.1) of the Act to a rollover XXX We agree with your interpretation that, although the partnership may own property referred to in subsection 59(2), a limited partnership interest is itself a capital property which is separate and distinct from the partnership property. ...

15 May 1981 Income Tax Severed Letter RCT 5-2312 F Unedited CRA Tags 84.1 Dear XXX: RE:     Application of Section 84.1 This is in reply to your letter of February 12, 1981 wherein you request our opinion concerning the application of section 84.1. ...

19 January 1984 Income Tax Severed Letter RCT 5-5728 F Unedited CRA Tags Reg. 4800(2) Dear XXX: RE:     Regulation 4800(2) We are writing in response to your letter of November 18, wherein you requested a technical interpretation concerning the meaning of the word "hold" as it is used in paragraph 4800(2)(a) of the Income Tax Regulations. ...