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18 October 1993 External T.I. 9325095 F- HAA7255-4 Qualifying Home Demolished & Rebuilt Unedited CRA Tags 146.01 XXXXXXXXXX Dear Madam: RE:  Qualifying Home under the Home Buyers Plan This is in reply to your letter of August 30, 1993, in which you request a ruling that a new modular home to be built on a new foundation will be a qualifying home under the home buyers plan where the new residence will be built on the same lot as your existing residence after it is demolished. ...

28 October 1993 External T.I. 9321245 F- Partnership- General & RRSP Unedited CRA Tags 96(1), 146(1) earned income XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Reporting Limited Partnership Rental Income and Expenses This is in reply to your letter dated July 15, 1993, requesting our interpretation as to how net rental income derived through a partnership interest, including a limited partnership interest, is to be calculated and reported for income tax purposes. ...

4 May 2001 External T.I. 2001-0081875- DEDUCTION OF FINES & PENALTIES Unedited CRA Tags 9(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 Department. ...

18 January 2002 External T.I. 2001-0116185- ERRORS & OMISSIONS INSURANCE Unedited CRA Tags 9(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. ...

9 December 1991 External T.I. 9121785 F- DSLP for Teachers — Calculation of Six Months Unedited CRA Tags ITR 6801(a) 5-912178  24(1) Dear 19(1) Re:  Deferred Salary Leave Plans Teachers in Semestered School Systems We are writing in reply to your letter of August 6, 1991, in which you ask us to reconsider the Department's position on counting the months of July and August for purposes of the above-noted leave plans.  ...

17 December 1991 External T.I. 9128055 F- Capital Gains Reserve — Extension of Due Date Unedited CRA Tags 40(1)(a)(iii) 912805 Dear 19(1): We are writing in reply to your letter of October 2, 1991, wherein you requested our views as to whether or not a person would be entitled to claim a reserve under subparagraph 40(1)(a)(iii) of the Income Tax Act (the Act) in the following situation. ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease CRA Tags 66(15) "Canadian resource property" 66.4 Principal Issues: How is an amount received for granting a lease of rights to explore for, drill for or extract petroleum, natural gas or other hydrocarbons reported for income tax purposes? ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

22 October 2013 External T.I. 2013-0503311E5- Class. of steel tanks & oak barrel for CCA purpose CRA Tags 125.1(3) "manufacturing or processing" ITR 1109 "manufacturing or processing" ITR Schedule II- Class 8 ITR Schedule II- Class 29 ITR Schedule II- Class 43 Principal Issues: Whether steel tanks and oak barrels used for fermenting/clarifying/blending and/or aging wine, and acquired after March 18, 2007 and before 2016, would be included in class 29 of Schedule II of the Income Tax Regulations. ... For further discussion in this regard, see IT-147R3, "Capital Cost Allowance – Accelerated Write-Off of Manufacturing and Processing Machinery and Equipment", which is available on the CRA's website. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves CRA Tags 110.6(1) 110.6(2) 66.4(5) 66(15) 110.6(1.3) 248 Principal Issues: Whether the taxpayer's farm would continue to meet the definition as a "qualified farm property", if oil reserves are discovered on the property. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

10 June 2015 External T.I. 2015-0580531E5- joint account & estate returns CRA Tags 104(13) 70(5) Principal Issues: TREATMENT OF PROPERTY HELD IN JOINT OWNERSHIP AT DEATH Position: LEGAL DETERMINATION REQUIRED Reasons: TAX TREATMENT DEPENDS ON LEGAL & BENEFICIAL OWNERSHIP OF THE PROPERTY. ...