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18 July 1990 Administrative Letter 901366 F- Donations and Trusts Unedited CRA Tags n/a 19(1) 901366   R. Mundell   (613) 957-2139   EACC9426 July 18, 1990 Dear Sir: Re:  Donations and Trusts This will reply to your letter of June 20, 1990 requesting an advance income tax ruling concerning purported "gifts" from patients. 24(1) We are unable to rule in this matter, as what constitutes a gift in any particular circumstance is a question of fact.  ...

XXXXXXXXXX Your Questions 10.      You requested our opinions on the following questions: (a)     If a provincial tax is an income tax that fits the wording of paragraph 18(1)(m) of the Act, would that tax initially be denied under paragraph 18(1)(a) of the Act? ... (c)     The OMT is an income tax. The Representative's Views 12.      ... This implies that a mining tax has been generally accepted as not deductible in computing income by virtue of paragraph 18(1)(a) of the Act. 20.       ...

5 September 1990 Administrative Letter 901136 F- Canadian Investment Income Unedited CRA Tags 20(1)(n), 12(1)(e)(ii), 125(7) specified investment business, 129(4) Canadian investment income, 129(4.1)   September 5, 1990 G. ... We understand this term to mean the funds of the taxpayer that do not constitute property that is: (a)     incident to or pertains to an active business carried on by the taxpayer, or (b)     used or held principally for the purpose of gaining or producing income from an active business carried on by it. ... Issue 4: 24(1)  You find support for your position in the following statement in paragraph 5 of Interpretation Bulletin IT-73R4:      "Where a corporation was incorporated to earn income by carrying on a business, there is a general presumption that profits arising from it's activities are derived from a business. ...

23 December 1991 Administrative Letter 9134466 F- Tuition Tax Credit Post-Secondary Course Unedited CRA Tags 118.5(1)(a)(i) 24(1)  —  118.5(1)(a)(i)  —  91–8592T We are writing in reply to your memorandum of December 13, 1991, wherein you requested our views as to whether or not (the college) would be considered to be an "other educational institution" for purposes of subparagraph 118.5(1)(a)(i) such that (the taxpayer) would be entitled to the tuition tax credit in respect of tuition fees paid to the college for the 1988 and 1989 taxation years. ...

For purposes of the Act the complete definition of a retiring allowance is:      "... an amount (other than a superannuation or pension benefit, an amount received as a consequence of the death of an employee or a benefit described in subparagraph 6(1)(a)(iv)) received      (a)  upon or after retirement of a taxpayer from an office or employment in recognition of his long service, or      (b)  in respect of a loss of an office or employment of a taxpayer, whether or not received as, on account or in lieu of payment of, damages or pursuant to an order or judgment of a competent tribunal by the taxpayer or, after his death, by a dependant or a relation of the taxpayer or by the legal representative of the taxpayer". ...

10 April 1992 Administrative Letter 9206576 F- Employee Profit Sharing Plan- Forfeitures Unedited CRA Tags 144(1) employees profit sharing plan   5-920657   D. ... Delorey   957-8953 April 10, 1992 Registered Plans Division Financial Industries S. ...

3 June 1992 Administrative Letter 9214426 F- Splitting RRSP Annuity Income Unedited CRA Tags 146(1) annuitant, 146(1) retirement income   7-921442   D.S. Delorey   957-8953 June 3, 1992 T1 Programs DivisionFinancial Industries DivisionJ. ...

2 May 1990 Administrative Letter 74756 F- Nova Scotia Tax Reduction for New Small Business Corporations Unedited CRA Tags 12(1)(x)   May 2, 1990 Halifax District Office Head Office Audit Review Section Specialty Rulings   Dave Turner Kevin McGuigan (613) 957-2094 SUBJECT: Nova Scotia Tax Reduction for New Small Business Corporations We are writing in reply to your memorandum of February 21, 1990, concerning whether the Nova Scotia tax reduction for new small business corporations (the "Reduction") should be brought into the taxpayer's income under paragraph 12(1)(x) of the Income Tax Act (the "Act"). ... Our Comments In our opinion, the Reduction should not be added back to the income of the taxpayer for the following reasons: 1)     Paragraph 12(1)(x) of the Act applies only to amounts received by a taxpayer in the year, in the course of earning income from a business or property.  ... For example, the following would be considered to be "inducements" and have to be added back to income under paragraph 12(1)(x) of the Act: a)     The Federal small business deduction, as it is an "inducement" to start a small business in Canada. b)     The manufacturing and processing profits deduction, as it is an "inducement" to start a manufacturing and processing business in Canada. c)     The difference between the higher provincial rates large corporations and the lower rates on income subject to the small business deduction, as the difference is an "inducement" to operate a small business.       ...

18 March 1993 Administrative Letter 9235556 F- Strip Bonds Unedited CRA Tags 12(9), 20(14), 20(21), ITR 7000 T2 & T3 Programs Division Financial Industries Division  Information Returns  Attention:  W. ... The verification follows: 25% 11% 8.5% Interest from Jan 1 to June 30, 1993 cost 300 x 25% x 182/365 = 37.39 350 x 11% x 182/365 = 19.19 360 x 8.5% x 182/365 = 15.25 Add to $ cost 300.00 350.00 360.00 337.39 369.19 375.25 Less coupon cashed 100.00 100.00 100.00 237.39 269.19 275.25 Interest from July 1, to Dec 31, 1993 237.39 x 25% x 183/365 = 29.76 269.19 x 11% x 183/365 = 14.85 275.25 x 8.5% x 183/365 = 11.73 267.15 284.04 286.98 less coupon cashed 100.00 100.00 100.00 167.15 184.04 186.98 Interest from Jan 1, to June 30, 1994 167.15 x 25% x 183/365 = 20.85 184.04 x 11% x 183/365 = 10.09 186.98 x 8.5% x 183/365 = 7.92 188.00 194.13 194.90 Less coupon cashed 100.00 100.00 100.00 88.00 94.13 94.90 Interest from July 1, to Dec. 31, 1994 88.00 x 25% x 183/365 = 11.03 94.13 x 11% x 183/365 = 5.19 94.90 x 8.5% x 183/365 = 4.05 99.03 99.32 98.95 Coupon cashed 100.00 100.00 100.00 difference because of rounding.97.68 1.05 These interest calculations were prepared globally for verification purposes only. ...

28 May 1990 Administrative Letter 59636 F- Definition of "Qualified Farm Property" Unedited CRA Tags 110.6(1) qualified farm property, 110.6(2), 248(1) personal trust 19(1) File No. 5-9636   R.B. ... With respect to the specific questions posed in your letter our comments are as follows. 1.      ... This definition will ensure that interests in partnerships that have ceased to carry on a business of farming in Canada because of the retirement of its partners will be included as qualified farm property of an individual provided that all or substantially all of the property of the partnership meets the 24 month use test.       ...