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The Queen 90 DTC 6662: a)        does the Department consider the receipt of strike pay to be non- taxable to the recipient? ... and c)        what type of organization does the Department consider to be a labour organization? Department's Position a)        A member of a union who is on strike or locked out need not include in income payments of the type commonly referred to as "strike pay" that are received from the union, even if the member performs picketing duties as a requirement of membership.  ...

Is equipment considered to be "available for use" for purposes of draft subsection 13(27) of the Income Tax Act (the "Act") in the following two situations?            ... Such alterations will be done in a subsequent taxation year.           In the second situation, equipment on hand at the end of a taxation year that is capable of producing commercially saleable products at the designed capacity in the taxation year produces nothing until one day after the end of the taxation year.            ...

21 December 1989 Income Tax Severed Letter ACC8874 F- Visit by Japanese Officials Unedited CRA Tags n/a   89M12053     December 21, 1989 Pauline McNally Provincial and International Director Relations Division Enquiries & Taxpayer Legislative and Assistance Division Intergovernmental Affairs Branch      E.E. Campbell      (613) 957-2067 VISIT BY JAPANESE OFFICIALS We want to express our tanks for the assistance which you, Joanne Ahearn and Norm O'Donnell gave in meeting with these gentlemen.  ...

1 December 1989 Income Tax Severed Letter 58343 F- Treatment of Interest Related to the Acquisition of Land Unedited CRA Tags 18(2), 20(1)(c), 18(2)(e), 20(1)(m), 18(3)(a)(i), 18(2)(f), 12(1)(a)   5-8343   D. Turner   (613) 957-2094   December 1, 1989 Dear Sirs: RE:     Subsection 18(2) of the Income Tax Act; We are writing in reply to your letter of June 29, 1989 concerning the treatment of interest related to the acquisition of land. ... Our Comments We offer the following comments relating to the above questions: 1)      The legal definition of land includes any items of a permanent nature found on the earth or attached to it. ...

5 July 1990 Income Tax Severed Letter 901033 F- Termination of a Supplementary Unemployment Benefit Plan Unedited CRA Tags n/a   July 5, 1990 Registration Directorate Ruling Directorate Registered Plans Division Financial Industries Division   W.C. Harding Attention: Stella Kotlar (613) 957-8953 Director     Your File: HAU 8303-4-2      REG 01134      J. Armstrong      901033      EACC9465 Subject: Termination of a Supplementary Unemployment Benefit Plan (a "SUB plan" and the Disbursement of the Plan Funds This is in reply to your memorandum of May 28, 1990 in request of our comments concerning the disbursement of funds on the termination of a Sub plan. ...

11 December 1989 Income Tax Severed Letter ACC8826 F- CIAT General Assembly in Mexico Unedited CRA Tags n/a     89M12307   December 11, 1989 Mr. George Venner Provincial and International Director General Relations Division Assessing and Enquiries Legislative and   Intergovernmental   Affairs Branch      E.E. ... One of these papers is topic 2.3 on the agenda entitled:      "Progress achieved in compliance with the administration of tax laws, with respect to taxpayer acceptance of taxes and promotion of voluntary compliance. ...

3 June 1991 Income Tax Severed Letter 91M06313 F- Requirements for Site Restoration Costs Unedited CRA Tags 18(1)(e), 18(1)(m) Question 17.       ... Such accruals are necessary to achieve proper matching of revenues and expenses.       ... There is no provision in Part I permitting the deduction of accruals under GAAP for site restoration costs.       ...

. *        Husband dies in 24(1). *        The husband's will provided for a spousal trust, that was resident in Canada.  ... In addition, the terms of the trust provided that:     a)   The spouse was entitled to receive all of the income of the trust, and     b)   No other person except the spouse may, before the spouse's death, receive or otherwise attain the use of any of the income or capital of the trust. 24(1) *        It is your view that, "provided a valid election is made under subsection 70(9.1), the land shall be deemed to have been disposed of for proceeds not greater than the fair market value of the land immediately before the death of the spouse and not less than the adjusted cost base of the trust immediately before the death of the spouse. ...

As a result, the taxpayer's tax liability on the periodic pension payment is Canadian tax before credit for state income tax ($4,000- $1,500) $2,500 Less: credit for state income tax $ (500) $2,000 U.S. federal tax before foreign tax credit $2,800 Less: U.S. foreign tax credit which is the lesser of $2,500 (Canadian tax before credit for state income tax) and $1,300 (U.S. federal tax of $2,800 less the U.S. source basis tax of $1,500) $1,300 $1,500 California State income tax $ 500 Total $4,000 Example II: Assume the same facts as in Example I except that the U.S. federal income tax on the periodic pension payment is $1,300 instead of $2,800. ... The tax liability of the taxpayer would be: Canadian income tax before credit for excess state income tax ($4,000- $1,500) $2,500 Less: credit for excess state income tax $ (300) $2,200 U.S. federal income tax (since U.S. federal tax is less than U.S. source basis tax, there is no U.S. tax credit in this case $1,300 California State income tax $ 500 Total $4,000 Example III: Assume the same facts as in Example I except that the Canadian income tax on the periodic pension payment is $3,000 instead of $4,000. ... The total tax liability of the taxpayer would be: Canadian income tax before credit for state income tax ($3,000- $1,500) $1,500 Less: Credit for state income tax $ (500) $1,000 U.S. federal income tax before tax credit $2,800 Less: U.S. foreign tax credit which is the lesser of $1,500 (Canadian tax before credit for state income tax) and $1,300 (U.S. federal tax of $2,800 less U.S. source basis tax of $1,500) $1,300 $1,500 California State income tax $ 500 Total $3,000 Issue # 2: Taxable Refund of State Income Tax Another issue is whether U.S. federal income tax on taxable refund of state income tax is creditable for Canadian foreign tax credit purposes. ...

(Tip Top Tailors Limited v MNR ~JL:Jump," (b)      A gain or loss on a loan forming part of the fixed capital of a business is on capital account. (Columbia Records of Canada Ltd. v MNR 71 DTC 5486) (c)      Where the proceeds of a foreign currency loan are used to acquire capital assets, there is a strong presumption that any resulting foreign exchange gain or loss is on capital account.  ... (Ethicon Sutures Ltd. v the Queen ~JL:Jump," (e)      Gains and losses on capital may not be recognized for income tax purposes until realized.  ...