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Yours truly, Director General Rulings Directorate Legislative & Intergovernmental Affairs Branch [SECTION: 55(3)(b)] VANCOUVER DISTRICT OFFICE ROUND TABLE May, 1992 Question 3 ...

We recommend that the words " proportionately as to 50% or more" be substituted thereto. ...

SUBJECT: AN EXEMPT INTEREST IN A PARTNERSHIP SECTION: 96(2.5)] PRAIRIE TAX CONFERENCE May 19 & 20, 1992 Question 9 DRAFT/EBAUCHE The Department of Finance's 1986 Technical Notes with respect to paragraph 96(2.5)(c) of the Income Tax Act suggests that the day-to-day operations or maintenance of the activity of a partnership that was carried on by the partnership on February 25, 1986 would generally not be considered to be a significant expansion of the activity. ...

Federal Surtax & Provincial Tax 1. Emigrants (page 1) The deeming provision in paragraph 2601(5)(a) of the Regulations applies for the purposes of Section 2601 of the Regulations. ...

You request our views regarding various alternative to the above situation: Our Views Our position remains as stated in answer to question 18 of the Thirty-Seventh Canadian Tax Foundation Conference, 1985 Revenue Canada Round Table Questions & Answers (a copy is enclosed for your convenience). ...

Ivey HEADQUARTERS Manager, John Oulton Policy & Technical Services 957-2141 Trust Accounts Division Attention: B. ...

SUBJECT: PRAIRIE TAX CONFERENCE (Q #12 NON-RESIDENT PARTNERS) SECTION: 233.1, 221(1)(d), REG 229(1)] April 27, 1992 PRAIRIE TAX CONFERENCE May 19 & 20, 1992 DRAFT/EBAUCHE Question 12 Does subsection 229(1) of the Income Tax Regulations ("Regulations") (Partnership Information Return- T5013) and section 233.1 of the Income Tax Act ("Act") (Information Return for Non-Arm's Length Transactions with Non-Residents- T106) apply to non-resident partners of a partnership that carried on business in Canada? ...

SUBJECT: PRAIRIE TAX CONFERENCE (Q #13) SECTION: 115(2)(c), 115(2)(e), 153(1), REG 104 (2)] April 27, 1992 PRAIRIE TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 13 Assume that an individual moved from Canada (severed all residential ties) to the United states in 1991. ...

Our Comments Paragraph 118.2(2)(e) of the Act provides that the amounts paid must be "... for the care, or the care and training, at a school, institution or other place of the patient, who has been certified by an appropriately qualified person to be a person who, by reason of a physical or mental handicap, requires the equipment, facilities or personnel specially provided by that school, institution or other place for the care, or the care and training, of individuals suffering from the handicap suffered by the patient;". ...

B) subsection 206(1) of the Act does not apply to the pooled fund since it is none of the entities described in section 205; C) units of the pooled fund will constitute foreign property within paragraph 206(2)(h) of the Act to XXX and D) the reference in each of paragraphs 206(1)(a) and 206(1)(b) of the Act to "... the fair market value at the time of its acquisition by a taxpayer... ...