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17 December 1981 Income Tax Severed Letter DATE: 17 December 1981 TO- Head Office Non-Corporate Rulings FROM- Source Deductions G E Moss 369-3666 ATTENTION Chief Non-Resident Business & Property Income RE: Estate & Trust Income Canada- U.K. ...

Snider, Section Chief FROM Specialty Rulings ' Advanced Audit & Investigations DE Directorate Training Programs Section J.E. ...

A penalty of 50% is charged on the amount by which the instalment interest exceeds the greater of • $1,000 or • 25% of the instalment interest calculated as if no instalment payment had been made for the year. ...

19 December 1990 Income Tax Severed Letter 902543 F- Notion of Control Unedited CRA Tags 85(4), 256(5.1) 24(1) 902543   M.P. Sarazin   (613) 957-2125 19(1) December 19, 1990 Dear Sirs: We are writing in response to your letter dated September 14, 1990 wherein you requested technical interpretations regarding the application of the provisions of subsection 85(4) of the Income Tax Act (Canada) (the "Act") to the following situations. ...

18 October 1990 Income Tax Severed Letter 902569A F- CCA for Mobile Homes Unedited CRA Tags n/a 24(1) 902569   C. Tremblay   (613) 952-1361 19(1) October 18, 1990 Dear Sirs: Re:  Capital Cost Allowances for Mobile Homes This is in reply to your letter of September 11, 1990, requesting a technical interpretation regarding the appropriate classification of mobile homes for capital cost allowance purposes. ...

12 September 1989 Income Tax Severed Letter 73669A F- Investment Tax Credit- Fishing Vessels Unedited CRA Tags 127(9) qualified property, 127(9) specified percentage, 255 19(1) File No. 7-3669   C.R. Bowen   (613) 957-2096 September 12, 1989 19(1) We are writing in reply to your letter of June 29, 1988, wherein you requested our interpretation as to whether new vessels which operate within Canada's 200 nautical mile fishing limit, but beyond the 12 mile territorial waters of Canada will be used "in Canada" for purposes of the definition of qualified property under subsection 127(9) of the Income Tax Act (the "Act") and therefore, will be eligible for investment tax credit ("ITC"). ...

24 August 1989 Income Tax Severed Letter 57674 F- Computation of Foreign Accrual Property Income (FAPI) Unedited CRA Tags 20(11), 20(12), 66(4), 91(1), 95(1) foreign accrual property income, 126(1), 126(2)(a) 19(1) File No. 5-7674   O. Laurikainen   (613) 957-2125 August 24, 1989 Dear Sirs: Re:  Computation of Foreign Accrual Property Income (FAPI) This is in reply to your letter of March 3, 1989.  ...

Yours reply, for Director Non-Corporate Rulings Division GJO'R/mn 56(1)(a)(ii) & (iii) 227(8) & (9) ...

Yours, for Director Non-Corporate Rulings Division GJO'R/mn 56(1)(a)(ii) & (iii) 227(8) & (9) ...

7 October 1990 Income Tax Severed Letter- Deductible Crown Rentals and Resource Profits Unedited CRA Tags Reg. 1204, 1204(d) Oil & Gas Issue Report # O&G 02 Deductible Crown Rentals and Resource Profits This is in reply to your memorandum dated September 26, 1990 wherein you request confirmation that the answer to a question (Question 21) regarding whether the tax treatment of certain lease rentals, which was prepared by the Rulings Directorate for the 1988 Rountable of XXX reflects the Directorate's current position with respect thereto. We confirm that there has been no change in the Directorate's position which was provided in the answer to question 21 of the 1988 Rountable of XXX Our understanding of the audit policy in your Oil and Gas Issue Report # O&G 02 is that Crown rentals which are deductible by virtue of Regulation 1211(d) should reduce resource profits computed under the provisions of Regulation 1204. ...