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Walker & Co. Ltd. v. I.R.C. [1920] 3 K.B. 648]. In more recent rulings, cap interest rates based on an effective overall yield to maturity of 13.5% per annum and a flat 12% per annum were accepted at the outset of the financings as reasonable limits. ... " [at p.6184] CURRENT POSITION AND OUTSTANDING ISSUES To date, to our knowledge, there have been no favourable rulings granted by the Department in respect of participation payments under paragraph 20(1)(e) of the Act. ...

Taylor wrote "... I do not agree with counsel for the respondent that only costs incurred while the automobile is in motion are qualified for deduction as travelling expenses.... ... During the course of the Commons debate on Bill C-139 (Commons Debates March 10, 1983 p. 23670) the Government was specifically asked to define operating costs to which the response was: "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road. ...

As per paragraph 2 of IT-172R "... where an individual has income from non-business (e.g., property held to earn investment income) he... is not subject to the above capital cost allowance restriction (i.e. ... Page 18 & 19- Capital Cost Allowance- Amount Claimable The Department of Finance uses the phrase "the half-year rule" rather than the "one-half year rule" used in the fifth line on page 18. ...

Provided that: (a) at the moment of the transfer described in paragraph 23 Amalco MFC is a mutual fund corporation within the meaning assigned by subsection 131(8) and the Fund is a mutual fund trust within the meaning assigned by subsection 132(6); (b) the property transferred at that moment has a fair market value of at least 90% of the fair market value of all property owned by Amalco MFC at that moment; and (c) Amalco and the Fund jointly elect by timely filing a prescribed form under paragraph (c) of the definition of “qualifying exchange” in subsection 132.2, the transfer described in paragraph 23 will constitute a “qualifying exchange” within the meaning of subsection 132.2(2), such that the rules in subsection 132.2(1) will apply to: • the transfer of the property from Amalco MFC to the Fund described in paragraph 23; • the purchase for cancellation by Amalco MFC of the Amalco MFC Class A shares and Amalco MFC Class B shares described in paragraphs 25 and 26; and • the transfer of the Fund Units from Amalco MFC to holders of the Amalco MFC Class A shares and the Amalco MFC Class B shares described in paragraphs 25 and 26. ... Provided that: (a) at the moment of the transfer described in paragraph 23 Amalco MFC is a mutual fund corporation within the meaning assigned by subsection 131(8) and the Fund is a mutual fund trust within the meaning assigned by subsection 132(6); (b) the property transferred at that moment has a fair market value of at least 90% of the fair market value of all property owned by Amalco MFC at that moment; and (c) Amalco and the Fund jointly elect by timely filing a prescribed form under paragraph (c) of the definition of “qualifying exchange” in subsection 132.2, as that subsection is proposed to be amended by subsection 72(1) of the Proposed Amendments, the transfer described in paragraph 23 will constitute a “qualifying exchange” within the meaning of subsection 132.2(1), as that subsection is proposed to be amended by subsection 72(1) of the Proposed Amendments, such that the rules in subsections 132.2(3) and (4), as proposed to be amended by subsection 72(1) of the Proposed Amendments will apply to: •the transfer of the property from Amalco MFC to the Fund described in paragraph 23; • the purchase for cancellation by Amalco MFC of the Amalco MFC Class A Shares and Amalco MFC Class B Shares and the transfer of the Fund Units from Amalco MFC to holders of the Amalco MFC Class A Shares and the Amalco MFC Class B Shares as described in paragraphs 25 and 26; and • the transactions described in paragraph 27. ...

The definition of "cumulative gains limit" and the relevant portion of the "annual gains limit" read as follows: ""cumulative gains limit" of an individual at the end of a taxation year means the amount, if any, by which (a) the total of all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 for A in the definition "annual gains limit", or (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (a) of the definition "annual gains limit" as it read in its application to those years exceeds the total of (b) all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 under paragraph (a) or (b) of the description of B in the definition "annual gains limit", (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (b) or (c) of the definition "annual gains limit" as it read in its application to those years, or (iii) an amount deducted under paragraph 3(e) by the individual for the individual's 1985 taxation year, (c) all amounts deducted under this section in computing the individual's taxable income for a preceding taxation year, and (d) the individual's cumulative net investment loss at the end of the year;" The description of "B" in the formula A- B found in the definition of "annual gains limit" reads in part, as follows: "B is the total of (a) the amount, if any, by which (i) the individual's net capital losses for other taxation years deducted under paragraph 111(1)(b) in computing the individual's taxable income for the year exceeds (ii) the amount, if any, by which the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses exceeds the amount determined for A in respect of the individual for the year, and b) all of the individual's allowable business investment losses for the year; " (emphasis added is ours) Note that the definitions of "annual gains limit" and "cumulative gains limit" as they read prior to the 1993 amendments would yield the same result provided that none of the gains or losses in question relate to non-qualifying real property. ...

Harding A/Manager, Policy & Technical Services 957-8953 Trust Accounts Division Attention: Lloyd MacKay 2000-001003 Retirement Compensation Arrangements ("RCAs") This is in reply to your memorandum of February 23, 2000, in which you asked us to respond to comments received by you with respect to our memorandum to you dated January 17, 2000, (our file 1999-001524). ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1-... ...

Government Assistance Issue The issues are twofold and relate to the position taken in our file # 9809735: 1. whether subsection 127(18) of the Act applies to net government assistance against the SR&ED qualified expenditures only where the government assistance is provided with respect to the construction of a building which will be used primarily for SR&ED, or whether it may also apply where the building will be dedicated primarily to manufacturing but in which substantial SR&ED will be performed, and 2. where the assistance (or a large portion thereof) is received and the building is constructed prior to the commencement of the SR&ED, whether the assistance which can be attributed to the SR&ED is to be netted in its entirety against the SR&ED qualified expenditures in the year such expenditures are first incurred, even if the result is a negative pool balance. ...

13 April 1992 Income Tax Severed Letter 9207126- Ontario Employee Wage Protection Program April 13, 1992 Other Returns & Guides Division Financial Industries Division P. ...

As a result of this calculation, the capital gain to be included in income from a 1992 disposition of a principal residence which has been owned since 1971 and which has been designated to be a principal residence for the taxation years 1988-1992 inclusive (for example, the years in which the deeming provision does not apply) would be the capital gain calculated in the normal manner for property held on Valuation Day (V-Day) less 6/21 (5+1 / 21) of the capital gain otherwise calculated. ...