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April 13, 2000 Client Services Directorate HEADQUARTERS Assessment & Collections Branch Karen Power, CA 25 McArthur Road, 1st Floor (613) 957-8953 Vanier, Ontario Attention: Betty-Ann Ward 2000-001844 XXXXXXXXXX- Taxation of Pension Benefits In response to your request of April 3,2000, we are providing you with the following insert to be included in your reply to a query raised by the above-noted taxpayer regarding the taxation of pension benefits. ...

PRINCIPALE QUESTION: Aux fins de l’alinéa b) de l’élément A du paragraphe 204.94(2) de la Loi, quel sens donne-t-on à l’expression “ régime qui ne compte aucun souscripteur”. ...

In this regard, "qualified expenditure" is defined in subsection 127(9), in part, as follows: " "qualified expenditure" incurred by a taxpayer in a taxation year means (a) an amount that is an expenditure incurred in the year by the taxpayer in respect of scientific research and experimental development that is an expenditure (i) for first term shared-use-equipment or second term shared-use-equipment... ...

This is evidenced by the precise wording of the provision which states in part: "(...) such of the trustees as the Minister may designate shall, for the purposes of this Act, be deemed to be in respect of all the trusts an individual whose property is the property of all the trusts and whose income is the income of all the trusts. ...

V Ltée verse annuellement à C Inc. une somme de 1 000 $ en considération de l'éxécution de son mandat. 8. ...

The Department made the following comments, which are still applicable to date, on this issue: "... ...

Kauffman Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...

Chief Resource Industries Section Bilingual Services & Resource Industries Division Rulings Directorate c.c. ...

Yours truly, for Director Reorganization & Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

In this letter you describe the following hypothetical situation: 1) A corporation (A Co.) is a Canadian-controlled private corporation, within the meaning of paragraph 125(7)(b) of the Act. 2) The assets of A Co. are: Term deposits $ 265,000 Inventory 3,000 Amounts due from related companies 1,424,000 Prepaid expenses 5,000 Fixed assets, at cost $442,000 Less depreciation 228,000 214,000 Investment in subsidiary 10,000 Deferred income taxes 16,000 1,937,000 3) A Co. carries on a business in Canada. ...