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Conclusion As the effect of the above described amendment to subparagraph 66(4)(b)(i) of the Act was to confirm the above long-standing position of the Department / Agency regarding the interpretation of that provision of the Act, we would not recommend that you follow the position taken in the Opinion. ...

Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

January 24, 2003 London Tax Services Office HEADQUARTERS Morris Zambon Bob Naufal, CMA Verification & Enforcement Division (613) 957-2744 2002-017628 1) Cost of Labour for M&P profits calculation 2) Revenue and salaries and wages paid by a partnership for purpose of Reg. 402(6) We are writing in response to your memorandum dated November 26, 2002, wherein you requested our interpretation of the phrase "fiscal period ending in or coinciding with" a taxation year in the circumstances described below. ...

Doug Williams HEADQUARTERS Toronto Centre Tax Services Office Randy Hewlett, B.Comm Verification & Enforcement Division 613-957-8973 2002-017767 Terminal Loss Deduction on Rental Properties We are writing in response to your memorandum of December 5, 2002, wherein you requested our opinion on the above-noted issue. ...

Therefore, subject to the new flow-through rules, if no election is made, our position as stated in the PEIB Q & A tax still applies. ...

John Oulton Manager Business, Property & Employment Income Section Income Tax Rulings and Interpretations Directorate- 2- ...

Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

The put option also stipulates that the Taxpayer will not be required to accept put options for more than XXXXXXXXXX % of the units from all producers in any one year, to be determined on a FIFO basis. e) Clause XXXXXXXXXX of the Agreement states: "...XXXXXXXXXX... ...

John Oulton Manager Business, Property & Employment Section III Business and Publications Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...