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There is clear authority from the courts that costs in connection with financing are expenditures on capital account unless the taxpayer is engaged in the business of lending money (Montreal Light, Heat & Power Consolidated v. ...

17 December 1991 Administrative Letter 9124586 F- Partnerships Unedited CRA Tags 20(1)(c) 19(1) (the "Taxpayer") This is in reply to your memorandum of September 4, 1991 in which you asked us to comment on previous Rulings opinions issued to the Belleville District Office regarding the Taxpayer and his investments in  24(1) We also acknowledge the additional information provided by 24(1) the taxpayer's representative in a letter to Kingston District Office Appeals dated July 19, 1991 and in a letter to Belleville District Office  —  Audit dated November 28, 1990.  ...

19 March 1992 Administrative Letter 9130266 F- Exempt Status of Salary and Allowance Unedited CRA Tags 81(1)(h) March 19, 1992 Client Assistance Business and Directorate   General Division Ms. ...

This position has recently found support, as evidenced by the Kieboom casecommentary found on page 13 of the CCH Tax Topics, Report # 1025; however, a caveat on its application is that the benefit must be received by the shareholder qua shareholder, as opposed to in some other capacity- see Winter et al v. ...

Should the US/CDN $ exchange rate require the implementation of the above-noted transaction, those paragraphs relating to: (a) the purchase of the XXXXXXXXXX (or a portion thereof) by XXXXXXXXXX, as described in 57; (b) the sale of the XXXXXXXXXX by XXXXXXXXXX, as described in 58; (c) the borrowing of funds as a daylight demand loan, as described in 59; (d) the subscribing for, and issuance of, Class XXXXXXXXXX Special Shares, as described in 61; and (e) the repayment of the daylight demand loans of XXXXXXXXXX, as described in 71; should be read such that references to the XXXXXXXXXX principal, the aggregate daylight demand loans, the aggregate subscription price of the Class XXXXXXXXXX Special Shares are equal to an amount that aggregates $XXXXXXXXXX or the US dollar equivalent of $XXXXXXXXXX CDN. ...

November 24, 1995 Appeals & Referrals Division HEADQUARTERS L. C. ...