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Robin Jackson Canadian Film & Videotape Certification Office Cultural Industries Directorate Department of Communications 16th Floor, Journal Tower South 365 Laurier Avenue, West Ottawa, Ontario K1A 0C8 Dear Robin: This is further to your letter of August 12, 1982 in connection with a proposal you have received from XXXX concerning XXXX While XXXX description concerning his proposals provide an illustrious description of his ideas and concepts, we are unable to draw definite conclusions as to whether or not any of the actual costs incurred will qualify as "computer software" within the meaning of paragraph (o) of class 12 of Schedule II to the Income Tax Regulations. ...

21 January 1985 Income Tax Severed Letter FOREIGN & SMALL BUSINESS SECTION D. ...

XXXX = 89%- see paragraph's 5 and 17 of Interpretation Bulletin IT- 171R) and therefore former section 118.91 would have denied a non- refundable tax credit otherwise allowable under section 118.1 except where the non-refundable tax credit otherwise permitted may reasonably be considered wholly applicable to the individual for the period or periods in the year throughout which he is resident in Canada, employed in Canada or carrying on business in Canada. ...

Paragraph 250(1)(d) of the Act provides: "For the purposes of this Act, a person shall... be deemed to have been resident in Canada throughout a taxation year if... he performed services, at any time in the year, in a country other than Canada under a prescribed international development assistance program of the Government of Canada and he was resident in Canada at any time in the 3 months' period preceding the day on which such services commenced", and Part XXXIV of the Income Tax Regulations provides: "... each international development assistance program of the Canadian International Development Agency that is financed with funds (other than loan assistance funds) provided under External Affairs Vote 30a, Appropriation Act No. 3, 1977-78, or another vote providing for such financing, is hereby prescribed as an international development assistance program of the Government of Canada". ...

Chief Finance, Insurance & Leasing Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

Section 2900 of the Income Tax Regulations defines " "scientific research" for purposes of sections 37 and 37.1 of the Income Tax Act as the "systematic investigation or search carried out in a field of science or technology by means of experiment or analysis," and goes on to make certain specific references to basic research, applied research and development. ...

10 April 1985 Income Tax Severed Letter DATE April 10, 1985 To- APPEALS BRANCH Appeals & Referrals Division FROM- RESOURCES INDUSTRIES SECTION G.R. ...

With regard to the out-of-court settlement, we would indicate that, in our view, this payment could not be considered an amount received "... as, on account or in lieu of payment of, or in satisfaction of a benefit under the Unemployment Insurance Act, 1971" (subparagraph 56(1)(a)(iv) of the Income Tax Act). ...

Chief Service Public Utilities & Exemption Corporation Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

This operation represents, in your opinion, the operation of a business activity. 5) The partnerships are located in Ontario & Quebec. ...