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(Tip Top Tailors Limited v MNR ~JL:Jump," (b)      A gain or loss on a loan forming part of the fixed capital of a business is on capital account. (Columbia Records of Canada Ltd. v MNR 71 DTC 5486) (c)      Where the proceeds of a foreign currency loan are used to acquire capital assets, there is a strong presumption that any resulting foreign exchange gain or loss is on capital account.  ... (Ethicon Sutures Ltd. v the Queen ~JL:Jump," (e)      Gains and losses on capital may not be recognized for income tax purposes until realized.  ...

31 October 1986 Income Tax Severed Letter RCT 6092-5 XXX proper interpretation of the phase "... in contemplation of... ... Problem: • the acquisition of the X Co. shares by Newco is not a transaction of the type detailed in subparagraphs 55(3)(b)(iii) through (viii); and therefore if this acquisition is "... in contemplation of... ... Position: • the transfer of the shares of X Co. to Newco was not considered to be in contemplation of the subsequent butterfly. • the denial in 88(1)(d) of a "bump" in respect of property transferred in the course of a butterfly only applies to property that is transferred directly or indirectly to a shareholder corporation in the course of a butterfly. ...

Crew confirmed the following:-     Deposits with a bank are unsecured, i.e. depositors rank as general creditors, rather than as secured or preferred creditors.-     Each deposit ranks pari passu, rather than being subordinate to, all other unsecured deposits (bank debentures under section 132 of the Bank Act, in contrast, are subordinate in right of payment to deposits).-     There are essentially three categories of deposit, as reflected by items 1, 2 and 3 of the Liabilities section of Schedule J, which is the Consolidated Return of Assets and Liabilities filed by a bank with the Superintendent of Financial Institutions: Item 1- Deposits payable on demand, Item 2- Deposits payable after notice, and Item 3- Deposits payable on a fixed date.-     There is no time limit for which a deposit may remain outstanding; e.g. a G.I.C. or other deposit instrument could exceed 5 years in term and still be reported as an Item 3 deposit as long as it ranks pari passu with other unsecured deposits (contrast with section 132 bank debentures which must have a term no less than 5 years but which are subordinate to deposits).-     Not all deposits are covered by C.D.I.C. insurance. Examples of amounts not insured:-     all amounts deposited by a particular depositor with a particular institution that exceed $60,000.-     deposits with fixed terms exceeding 5 years.-     foreign currency deposits or amounts deposited with a branch outside Canada-     Most, but not all, deposits are taken into account in determining the bank's reserves.-     Any amount not reported in items 1, 2 and 3 of the Liabilities section of Schedule 3 is not a deposit. ...

In forming our opinion, we gave consideration to the following points: 1.      ... (c)       Subsection 74.1(1) of the Act contains the following exclusion from amounts otherwise attributable under that subsection:      "otherwise than by an assignment of any portion of a retirement pension pursuant to section 64.1 of the Canada Pension Plan or a comparable provision of a provincial pension plan as defined in....)".      Such pension income would be taxed under section 56 of the Act (i.e., subparagraph 56(1)(a)(i)).  ...

Bowen (613) 957-2096 Dear Sirs: Re: Scientific Research and Exnerimental Development ("SR & ED") We are writing in reply to your letter of June 15, 1990, wherein you requested our comments on I) the deductibility of SR & ED expenses under paragraph 18(1) (a) of the Income Tax Act (the "Act") and 2) the availability of investment tax credit ("ITC") to a company performing SR & ED activities on behalf of another taxpayer. ... Where a limited partnership carries on SR & ED activities and chooses to deduct the expenses under paragraph 18(1)(a) of the Act, rather than subsection 37(1) of the Act, will the restriction on the deductibility of SR & ED expenses provided for in paragraph 96(1)(g) of the Act be applicable? ... Where a limited partnership, which chooses to deduct its SRD expenditures under paragraph 18(1)(a) of the Act, has entered into an agreement with a company under which the company will carry on SR & ED activities on behalf of the partnership, will that company be entitled to ITC on such SR & ED expenditures? ...

DEPARTMENT'S POSITION In his speech of December 16, 1987, to the House of Commons on Tabling the Notice of Ways and Means Motion relating to the implementation of Tax Reform, the Minister of Finance made the following comments:      "The vast majority of families with children will pay substantially less personal income tax as a result of the White Paper proposals.       ... " Among the improvements announced was the following:      "To target additional assistance to larger families, the child credit for the third and each subsequent child in the family is being doubled to $130." He went on to say:      "These measures incorporate a number of suggestions from the House Committee on Finance and Economic Affairs.        ...

2.       Why isn't there an exception from the "2-year hold" rule in the case of death?  ... 3.a)     Are the shares of X Co. rolled over to Mrs. A on A's death? ... Or, does Revenue Canada still take the view that the Parkes Estate case was properly decided. b)      Had Mr. ...

3 June 1991 Income Tax Severed Letter 91M06315 F- Flow-through Shares- Prescribed Shares Unedited CRA Tags 6202.1(1)(c), 66(12.73), 6202.1 Question 20.      ... Answer 20.     We reiterate our answer to this question which was asked in Question 7 at the 1990 Roundtable (Canadian Petroleum Tax Journal, Fall 1990, page 141):      Provided the issuer agrees to pay damages to the subscriber only to the extent of any additional tax payable by the subscriber as a consequence of a reduction of the expected tax deductions pursuant to subsection 66(12.73) of the Income Tax Act, it is our view that such an indemnity would not cause any issued shares to be prescribed shares within the meaning of section 6202.1 of the Regulations.      It is also our view that where no shares have been issued in respect of any unspent proceeds, the issuer agrees to refund such proceeds to the subscriber, and the price of any shares subsequently issued will not be reduced because of the refund, such an indemnity would not cause the prescribed share rules to apply.       ...

A taxpayer is preparing a request for an advance income tax ruling and is desirous of submitting the request in such manner that would facilitate processing of the ruling request.       ... Our records show that the necessity of having to make repeated requests for information or documents is the principal reason why there is, in far too many cases, a slow turnround time.       ... Nevertheless, as part of our review, we do want to see all relevant documentation and agreements.       ...

It is our view that, in these circumstances, the truck could qualify as a SR & ED capital expenditure, notwithstanding that the nature of the asset and its direct use do not necessarily impart the typical image of SR & ED activities. ... Secondly, to qualify, the truck must be an expenditure that is intended to be used for or in the prosecution of SR & ED. ... It is our view that the truck allows the taxpayer to carry on or engage in SR & ED. ...