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1 November 1991 Income Tax Severed Letter 91M11251 F- Government Guarantee of a Partner's Loan on At-Risk Rules Unedited CRA Tags 96(2.4)(b), 96(2.4)(d) QUESTION 6.      ... Therefore, such limited recourse borrowings will reduce the limited partners' at-risk amount.            ... ANSWER 6.     For purposes of the partnership at-risk rules, it is our view that a guarantee of a partner's loan which is used to finance all or a portion of the purchase price of a partnership interest would be treated in the same manner as limited recourse or non- recourse financing of acquisitions of partnership interests. ...

1 November 1991 Income Tax Severed Letter 91M11264 F- Mining Steering Committee Meeting QUESTION 3.        In order to be included in Class 28 by virtue of subparagraph (b)(ii) thereof, an asset must be acquired in the course of and principally for the purposes of an expansion that constitutes a major expansion of the mine and there must be an increase in the greatest designed capacity of the mill that processed the ore from the mine, measured in tons of input of ore, of not less than 25%.     ... ANSWER 3.        For purposes of Class 28, it is our view that in the absence of a mill that processes the ore from a mine, there would not be a major expansion to the mining operation solely by virtue of acquisition of an asset that increases ore recovery by greater than 25%.  ...

14 November 1989 Income Tax Severed Letter AC4131G1B F- Canada-Germany Social Security Agreement Unedited CRA Tags n/a 19(1) 19(1)   A. Watson   (613) 957-2072   HBW 4131-G1 November 14, 1989 Dear 19(1) Re: 19(1) This is in answer to your letter, dated September 21, 1989 in which you request our concurrence in special arrangements under Article 10 of the Agreement on Social Security between Canada and the Federal Republic of Germany. ... Savage A/Director Provincial and International Relations Division c.c.       ...

1 November 1991 Income Tax Severed Letter 91M11262 F- Minerals Extracted from a Mineral Resource and Minerals from Producing Industrial Minerals not Finished Goods QUESTION 6.        ... ANSWER 6.        It is our view that minerals extracted from a mineral resource and the minerals from producing industrial minerals which have not yet been subsequently manufactured or processed would not constitute finished goods for purposes of subparagraph 127(11)(b)(i) of the Act and paragraph (d) of the definition of "qualified activities" in Regulation 5202.  ...

Convention (1978) has been brought to the attention of P & I by XXXX The Problem involves a Canadian corporation borrowing Canadian dollars from a United Kingdom lender. ... Convention XXI " " " XI- paragraph 7 of OECD model XXI ...

Francis 957-3496 SUBJECT: XXX 7-4121 Employee Pension Plan This is in reply to your memorandum of July 10, 1989, wherein you requested our opinion in respect of the following situation: • XXX • XXX • XXX • XXX • XXX • XXX You have requested our views in respect of three specific issues: 1. ...

An example of this tax reduction is as follows: Canadian Employment Income $59,000 Interest Income from Canadian sources $1,100(A) Less: Expenses incurred to earn the Canadian interest income 100 1,000(B) Net Income $60,000 Deductions in computing taxable income 10,000 Taxable Income $50,000(C) Total Federal and Provincial Taxes Payable @ 40% Rate C X 40% = $50,000 X 40% = $20,000(D) Taxes Payable relating to Canadian Interest Income B X D = $ 1,000 X $20,000= $ 400(E) C $50,000 Limitation under paragraph 2 of Article 11 of the Convention 10% X A = 10% X $1,100 $ 110(F) Tax Reduction E- F = $400- $110 = $ 290(G) Note: The tax reduction should be apportioned on a reasonable basis between the Federal and Provincial taxes payable. Revised Taxes Payable D- G = $20,000- $290 = $19,710 Please note that this approach produces the correct net income amount which is used for the purposes of calculating various tax credits. ... An example of this is as follows: • A Japanese citizen earns investment income (i.e. interest) arising in Japan and is required to pay tax to the Japanese Government on such income. • The tax paid to the Japanese Government would qualify as a non- business income tax as defined in paragraph 126(7)(c) of the Act except for the portion, if any, of the tax that may be deductible under subsection 20(11) of the Act. • Such foreign source interest income should be exempt from tax in Canada by virtue of paragraph 1 of Article 20 of the Convention. ...

6 December 1990 Income Tax Severed Letter 902633 F- Transfer of Non-resident's Interest in Partnership Unedited CRA Tags 85(1.1), 85(1), 245      File 902633 1990 Round Table QUESTION I50 Section 85 Transfer by a Non-resident Real property, an interest therein or an option in respect thereof that is owned by a non-resident person (other than a non-resident insurer) does not qualify as "eligible property", as defined in subsection 85(1.1), for the purposes of an election pursuant to subsection 85(1). ...

Thus the capital cost for purposes of sections 13 and 20 is deemed to be $24,489, calculated as follows: (A) $24,489 + (B) 3/4 x ((I) $42,020- (II) $24,489 + (III) 4/3 x $13,148) = $24,489 + 3/4 x (42,020-(24,489 + 17,531=42,020)) = $24,489 + (3/4 x 0) = $24,489. ...

1 February 1990 Income Tax Severed Letter 9195 F- Form T691A Minimum Tax Supplement- Multiple Jurisdiction Unedited CRA Tags n/a                                      February 1, 1990   Assessing & Enquiries Directorate  Technical Interpretations J.M. ... Middleton             Division               957-9230 Nancy Kelly Subject: Form T691A Minimum Tax Supplement- Multiple Jurisdiction In accordance with your request of October 25, 1989, we have reviewed the above-mentioned form. ...