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12 February 2002 External T.I. 2001-0081025- INTEREST DEDUCTIBILITY Unedited CRA Tags 20(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Storry February 12, 2002 Dear XXXXXXXXXX: Re: Paragraph 20(1)(c) of the Income Tax Act (Canada) (the "Act") We are writing in response to your correspondence of April 23, 2001, wherein you requested our views on whether interest on borrowed funds used for the purpose of earning income from property is deductible where some of the leveraged investment is withdrawn by the individual. ... To the extent that it relates to a past transaction you should contact the appropriate Tax Services Office ("TSO") of the Canada Customs & Revenue Agency (the "CCRA"). ...

14 February 2002 External T.I. 2001-0102035- QUALIFIED INVESTMENT CERTAIN INDEX FUND Unedited CRA Tags 146(1) reg 4900(1)(N.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Sarazin, CA February 14, 2002 Dear XXXXXXXXXX: Re: XXXXXXXXXX and Qualified Investment for an RRSP This is in reply to your letter of September 11, 2001, requesting our views as to whether a unit of the XXXXXXXXXX would be a "qualified investment" for a registered retirement savings plan ("RRSP") within the meaning assigned by subsection 146(1) of the Income Tax Act (the "Act"). ... Under paragraph 4900(1)(n.1) of the Regulations, qualifying units include Standard & Poor 500 Depositary Receipts (known as SPDRs), units valued on the basis of the Dow Jones Industrial Average (known as DIAMONDs) and units for a particular country (known as WEBs) valued on the basis of the Morgan Stanley Capital Investment Index. ...

18 June 2002 External T.I. 2001-0115875- RESEARCH ACCOUNTS Unedited CRA Tags 5(1) 56(2) 6(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... June 18, 2002 XXXXXXXXXX Tax Services Office HEADQUARTERS Verification & Enforcement Division Randy Hewlett, B.Comm. ...

7 May 2002 External T.I. 2002-0127485- COST PLUS HEALTH PLANS Unedited CRA Tags 6(1)(a) 248 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Principal Issues: PHSP for self-employed person and his immediate family (Cost-plus plans) Position: Lacks necessary element of insurance Reasons: Prior letters 1999-0014245,9904155, 2002-012748 CALU Question # 3 COST PLUS HEALTH PLANS AND PARNERSHIPS/PROPRIETORSHIPS Over the past several years, CCRA has issued a number of interpretation letters issued dealing with private health services plans (PHSP's) and cost plus plans. ...

20 May 2002 External T.I. 2002-0117885 F- Lien de dépendance et application de 120.4 Unedited CRA Tags 120.4 251(2) 104(1) et (13) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-011788 Éric Allard-Pouliot Le 20 mai 2002 Monsieur, Objet: Demande d'interprétation technique Application de l'article 120.4 et du paragraphe 251(2) de la Loi de l'impôt sur le revenu La présente fait suite à votre lettre du 9 janvier 2002 relativement à l'application de l'article 120.4 et du paragraphe 251(2) de la Loi de l'impôt sur le revenu (ci-après la " Loi "). ...

April 8, 2002 XXXXXXXXXX Jane Stalker Tel: (613) 946-8764 Fax: (613) 941-5932 ID# 2002-112588 HBW # 4125-4/49 HBW #4125-7/18 Dear XXXXXXXXXX: Re: Pensions received from Germany We are responding to your facsimile received March 25, 2002, in follow up to our telephone discussion, in respect of the tax treatment of certain pensions received by Canadian residents from Germany. The new Canada-Federal Republic of Germany Tax Agreement (the "new German treaty") entered into force on March 28, 2002. ... " As the new German treaty entered into force in 2002, new subparagraph 3(c) of Article 18 would not generally apply for 2001 and 2002 since the old German treaty, under which only Germany had the right to tax these payments, presumably gives greater relief. ...

22 July 2002 External T.I. 2002-0135265- NPO SOCIETY Unedited CRA Tags 149(1)(l) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-013526 Bob Naufal, CMA (613) 957-2744 July 22, 2002 Dear XXXXXXXXXX: RE: TECHNICAL INTERPRETATION REQUEST- TAX EXEMPT STATUS This is in reply to our phone discussion (Naufal/XXXXXXXXXX) on April 9, 2002 and your letter of April 14, 2002, wherein you requested our views regarding whether XXXXXXXXXX (the "Entity") qualifies as a non-profit organization pursuant to the Income Tax Act (Canada) (the "Act"). ... To the extent that it relates to past transactions you should contact the appropriate Tax Services Office of the Canada Customs & Revenue Agency (the "CCRA"), since the review of such transactions falls within their responsibility. ...

29 July 2002 External T.I. 2002-0140205- MEANING OF AIR PURIFIER Unedited CRA Tags 118.2(2)(M) R.5700(C) R.5700(C.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Gibbons, CGA July 29, 2002 Dear XXXXXXXXXX: We are replying to your email, dated May 9, 2002, about whether certain products (the "particular products") manufactured by XXXXXXXXXX (the "Manufacturer") would qualify as a medical expense under subsection 118.2(2) of the Income Tax Act (the "Act"). ... According to Merriam- Webster's Collegiate Dictionary (Tenth Edition) "purify" may mean "to make pure: as... to free from undesirable elements", " while The Concise Oxford Dictionary (Eight Edition), states that the term may mean to "cleanse or make pure. ...

Principal Issues: Whether reimbursement of tuition fees would fall within the guidelines set out in ITTN 13 when the fees are XXXXXXXXXX % reimbursed after the employee has been with the employer for XXXXXXXXXX years following the course, and fully reimbursed after XXXXXXXXXX years.. ... XXXXXXXXXX Wayne Antle, CGA 2002-014670 September 13, 2002 Dear XXXXXXXXXX: Re: Reimbursement of Tuition Fees This is in response to your letter of June 10, 2002, concerning whether the reimbursement of tuition fees by the XXXXXXXXXX (the "employer") for its newly-hired recruits would be considered a taxable employment benefit to the employees. In your letter and our telephone conversation on September 9, 2002 (Antle/XXXXXXXXXX), you summarized the facts as follows: The employer sometimes recruits individuals to work as uniformed police constables. ...

XXXXXXXXXX 2002-012967 Annemarie Humenuk November 12, 2002 Dear XXXXXXXXXX: Re: Powers of Appointment This is in reply to your letter of March 13, 2002, concerning the tax consequences arising on the death of an individual who holds a general power of appointment over property held in a testamentary trust. ... As stated in Oosterhoff's Text Commentary & Cases on Trusts, an instrument which purports to grant a power of appointment may be construed as creating a discretionary trust, a power of appointment or an outright gift. ... As requested, we enclose a copy of your letter dated March 1, 2002. We trust our comments will be of assistance. ...