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25 November 1988 Income Tax Severed Letter 95-6671 F Dear Sirs: RE:     Sovereign immunity XXX In reply to your letter of September 27, 1988, the comments contained in our letter of April 1, 1989 would apply irrespective of whether the particular branch of the XXX were located in or outside XXX provided the conditions set out in paragraph 47 of Information Circular 77-16R3 are met. ...

10 November 1988 Income Tax Severed Letter 9HAV 8812-3 F Dear XXX RE:     Subsection 13(7.4) Election This is in response to your letter dated September 22, 1988, addressed to Mr. ...

16 November 1982 Income Tax Severed Letter RCT 5-1787 F RE:     Definition of Canadian-controlled private corporation Paragraph 125(6)(a) defines a "Canadian-controlled private corporation" is "a private corporation that is a Canadian corporation other than a corporation controlled... by one or more public corporations (other than a prescribed venture capital corporation)... ...

18 June 1987 Income Tax Severed Letter 95-3337 F Dear Sir: RE:     Clause 212(1)(b)(iii)(D) of the Income Tax Act (the"Act") This is in reply to your letter of May 4, 1987 concerning the status of the Regulations with respect to the above noted clause of the Act. ...

24 February 1986 Income Tax Severed Letter 95-0341 F Dear Sirs: RE:     Technical interpretation requested concerning sections 94 and 95 of the Income Tax Act (the "Act") We are writing in response to your letter of December 23, 1985 in which you requested our interpretation of the above-noted provisions of the Act its applied to a fact situation detailed therein. ...

18 May 1988 Income Tax Severed Letter 95-6006 F Dear Sirs: RE:     Disability Pension This is in response to your letter of May 2, 1988. ...

.:     5 19(1) 5-9320 December 29, 1989 Dear Sirs: Re:  Advance Income Tax Ruling 3-2453 dated October 2, 1989 ("Ruling") 24(1) This is in reply to your letter dated December 28, 1989, wherein you advised that the proposed transactions set forth in the Ruling will not be completed by December 31, 1989 as contemplated in the Ruling. ...

Since, in our view, the performance of SR & ED on a contract for fee basis constitutes the provision of services as opposed to the manufacture and sale of a good it is our view that subparagraph 125.1(3)(b)(x) would normally apply to disqualify a company whose sole business is the performance of SR & ED for profit from claiming the deduction from tax provided by section 125.1 of the Act. ... Thus, in circumstances where a substantial portion of a taxpayer's revenue is derived from the sale of prototypes and it was intended or reasonably expected at the outset of the projects that the prototypes would be sold, it is our view that the taxpayer does not derive all or substantially all of its revenue from the prosecution of SR & ED or the sale of rights in or arising out of SR & ED. Relating these comments to our response to your second concern it is possible that the non-SR & ED portion of the taxpayer's activities could constitute the manufacture of goods for sale or lease and that although the taxpayer would not be entitled to the various SR & ED incentives for all of its expenditures it is possible that the taxpayer may qualify for the deduction from taxes payable provided by section 125.1 of the Act. ...

2 January 1980 Income Tax Severed Letter RCT 7-1011 F Unedited CRA Tags 85, 85(1)(e.2), 69 RE:     Cooperative Corporations This is in reply to your memorandum of October 1, 1980 and further to our recent telephone conversation. ...

18 November 1982 Income Tax Severed Letter RCT 5-3706 F Unedited CRA Tags 85(1), 98(5) Dear Sirs: RE:     Transfers of resource partnership interests to corporations under subsection 85(1) of the Income Tax Act This is in reply to your letter of January 19, 1982 in which you requested clarification of the Department's position on subsection 85(1) rollovers of resource partnership interests to corporations. ...