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Reasons: 1) & 2) Wording of the Act XXXXXXXXXX 2003-002965 Shaun Harkin, CMA October 20, 2003 Dear XXXXXXXXXX: Re: Technical Interpretation Request: Tax Treatment of Partnership Interest This is in reply to your letter of July 8, 2003 wherein you asked for our comments in respect of the following hypothetical situation:? ...

Yours truly, Jim Wilson for Director International & Trusts Division Income Tax Rulings Directorate- 3- ...

Other Comments Pursuant to paragraph (g.1) of the definition of "Canadian exploration expense" ("CEE") in subsection 66.1(6) of the Income Tax Act (the "Act"), expenses incurred by a taxpayer that qualify for inclusion in "Canadian renewable and conservation expense" (" CRCE", as defined in the above subsection of the Act) will also be included in the taxpayer's CEE. ...

., states as follows: "--- I would add only this: the Income Tax Act, read as a whole, envisages that a distribution of corporate surplus to shareholders is to be taxed as a payment of dividends. ...

Yours truly, Olli Laurikainen, Manager for Director International & Trusts Division Income Tax Rulings Directorate- 1- ...

Vous avez investi 10 000 $ dans une fiducie régie par un REER et cette dernière a acquis 10 000 parts d'une coopérative. ...

Reference may be had to CCRA Interpretation Bulletin IT-226R, "Gift to a Charity of a Residual Interest in Real Property or an Equitable Interest in a Trust " in this respect, which is available on the CCRA website at http://www.ccra-adrc.gc.ca/E/pub/tp/it226r/it226r-e.html. ...

., Manager for Director International & Trusts Division Income Tax Rulings Directorate- 3- ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 1- ...

. $50,000 @ 20% per year)? Our comments The situation that is described in your letter appears to involve a series of completed transactions involving specific taxpayers. ...