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16 October 1989 Administrative Letter 58556 F- Meaning of "the Prime Metal Stage or its Equivalent" Unedited CRA Tags 1204(1) Director General Tax Policy Analysis Division File No. 5-8556 Energy, Mines & Resources Canada G.R. ... In the case at issue, 19(1) has framed its questions in the context of processing bauxite ore where there is a series of commercial products arising in the processing of such ore into aluminum ingots. 19(1) has asked the following questions on which we request your comments on: 1.       ... 3.      Does the answer to question 2 turn on whether a particular taxpayer processes and sells alumina as a primary product with say only a portion of the alumina processed further by him and sold as aluminum ingots, i.e. can the "prime metal stage" of a specific ore bauxite- change as between taxpayers or is it constant once industry usage as a whole is established? ...

& 2.     If the company gives an employee a notice of termination, for example of one (1) month, but tells the employee if you leave immediately we will pay you for that month in addition to the amount in respect of the termination of employment, will that additional amount constitute a "retiring allowance"?       ... These constitute the payments that will be considered as retiring allowances. 4.     Retiring allowances need not be paid in a lump sum amount but may be paid over several months or years by way of fixed periodic amounts.       ...

12 September 1989 Administrative Letter F3186 F- Information Circular 73-21R7: Away-from-home Expenses Unedited CRA Tags 67.1, 8(1)(h), 8(10)   September 12, 1989 Examination Division Current Amendments and   Regulations Division Attention:  S. ... We hope our suggestions will assist you in making further clarifications. 2.       ... Taxpayers using this circular may be looking for guidance on this matter. 3.       ...

2 February 1994 Administrative Letter 9337336 F- Indians- Employment Agency Unedited CRA Tags 5(1), 9(1), 81(1)(a) February 2, 1994 Source Deductions Division     Head OfficeDistrict Office and Taxation Centre      Rulings DirectorateSupport Services      957-8953 Attention:  R. ... Albert for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch cc.       ... Owen, Client Services Directorate     David Cowie, Vancouver District Office ...

24 January 1992 Administrative Letter 9201966 F- Charitable Foundation Unedited CRA Tags 149.1(1) charitable foundation, 149.1(3) January 24. 1992 Trish Gorie     Business and General Charities Division       Division 5th Floor     H. ... Facts 24(1) Proposed Transactions 24(1) Purpose of the Proposed Transactions It is our understanding that the purpose of this series of transactions is:       (i)     to allow certain researchers at 24(1) to participate in the profits realized as a result of their work, and (ii)     to qualify for certain refundable tax credits offered by the province of Quebec.  ... NCorp's Default on Loan 24(1) may assist NCorp obtain financing in one of two ways: (i)     provide a loan guarantee, or (ii)     pledge its assets as security for the loan. ...

27 August 1990 Administrative Letter 901776 F- Non-profit Organizations Unedited CRA Tags 149(1)(l)   901776   Bill Guglich   (613) 957-2102     EACC 9257 Attention: 19(1) August 27, 1990 Dear Sirs: This is in reply to your letter of August 13, 1990 concerning the impact of the Goods and Services Tax (GST) Legislation on the tax status of a non-profit organization (NPO) under paragraph 149(1)(1) of the Income Tax Act (the Act). ...

3 September 1991 Administrative Letter 91M09256 F- Tenant Inducements Unedited CRA Tags 12(1)(x)       Question What are Revenue Canada's current assessing practices regarding tenant inducements?  ...

Dath DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.      Technical Publications Division      John Oulton, Acting Director ...

31 October 1989 Administrative Letter 89M10506 F- Request for Remission of Tax Unedited CRA Tags 159(3)   October 31, 1989 TO- VANCOUVER DISTRICT OFFICE FROM- Technical  Mr. ... Seguin Interpretations Division Director- Taxation Greg Middleton   (613) 957-9230 Attention: Mr. ... We are also enclosing: (1)      19(1) T1 Returns for the years 1980 to 1987 plus his permanent envelope; and (2)      19(1) T1 Returns for the years 1979 to 1981 plus his permanent envelope. ...

Hence, based on the express wording of the subsection, we are of the view that the loss-reduction rule contained therein applies (assuming that the exception provided by paragraphs 112(4)(a) and (b) is not available) even where: (a)      the shares in question are shares of a corporation not resident in Canada; and (b)     the dividend received on such shares is not deductible. ... The portion of subsection 4(4) which is relevant to this analysis is:      ... no provision of this Part shall be read or construed to require the inclusion... in computing the income of a taxpayer for a taxation year or his income or loss for a taxation year from a particular source... of any amount to the extent that amount has been included... in computing such income or loss under, in accordance with or by virtue of any other provision of this Part.       ... Accordingly, paragraph 12(1)(k) and subsection 112(4) may both apply, without offending subsection 4(4). 3.      ...