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September 4, 2003 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Tax Services Office Rrandy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2003-000976 Subsection 1101(5d) of the Income Tax Regulations (the "Regulations") We are writing in response to your memorandum of March 24, 2003, wherein you asked for our opinion on an issue involving a taxpayer's classification of railway cars pursuant to the above-noted provision. ...

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

We are only able to provide definitive comments on the income tax implications that may arise when transactions occur between persons not dealing with each other at arm's length in the context of a particular fact situation Therefore, when employment is ruled not insurable because the persons are considered not to be dealing with each other at arm's length at a particular time, and there is some concern that this decision could also have income tax implications, then the issue should be discussed with a technical advisor in the Verification & Enforcement Division ("V&E") of the applicable tax services office. ...

November 17, 2003 XXXXXXXXXX TSO HEADQUARTERS XXXXXXXXXX Income Tax Rulings Verification & Enforcement Division Directorate Randy Hewlett, B.Comm 613-957-8973 2003-004678 Application Of Subsection 20(7)- Software Maintenance Plans We are writing in response to your e-mail of November 3, 2003, wherein you provided us with a copy of a letter from XXXXXXXXXX (the "Taxpayer"), submitted to you in response to our memorandum of October 7, 2003 (our file 2003-003794). ...

Verification & Enforcement Division 613-957-8973 XXXXXXXXXX Tax Services Office 2003-003534 Application Of The "Available For Use Rules" To A Building We are writing in response to your letter of August 11, 2003, wherein you requested our view on the application of the "available for use rules" under the Income Tax Act (the "Act"), as it pertains to a building being constructed by XXXXXXXXXX (the "Taxpayer"). ...

If you have questions on a specific matter with respect to the determination of an employment status, please contact the CPP / EI Eligibility Division of the Assessment and Collections Branch. ...

Brian Olsen HEADQUARTERS Northern BC & Yukon Tax Services Office Randy Hewlett, B.Comm. 613-957-8973 2004-006490 Definition of "Passenger Vehicle"- Income Tax Act ("the ITA") We are writing in response to your request for our opinion on the definition of "passenger vehicle" in subsection 248(1) of the ITA, as it pertains to certain motor vehicles that are used in a business activity which is not considered a "commercial activity" for purposes of the Excise Tax Act (the "ETA"). ...

It should be taxed in the same proportion as the subsequent / resulting employment income. ...

" As you note, paragraph 87 of IT-151R5 states, in part "... corporations (and associated corporations) whose taxable capital employed in Canada in the previous taxation year... exceeds $15 million will not have a business limit (see paragraph 81) and, therefore, will not meet the conditions to be a qualifying corporation. ...

Lloyd Clark & Co. Ltd. (1970 CarswellNat 142), the Tax Appeal Board stated: "...that payment of a purchase price is basically not effected by the delivery of a promissory note unless the governing agreement for sale provides specifically for that particular mode of payment... ...