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8 June 1998 External T.I. 9806285- RRSP- FOREIGN PROPERTY & REINVESTED EARNINGS-- summary under Subsection 206(2) Summary Under Tax Topics- Income Tax Act- Section 206- Subsection 206(2) The cost amount of units of a mutual fund trust that is foreign property include the amount of dividend distributions that have been reinvested in additional units. ...

23 March 1994 Administrative Letter 9332416 F- Japan Inhabitant's Tax — Income or Profits Tax-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The municipal inhabitant's tax imposed by Japan is an income tax with the exception of any per capita tax included in that tax. ...

27 June 1994 External T.I. 9410195- LARGE CORPORATION TAX & CONDITIONAL SALES CONTRACTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Where a party (other than a financial institution) acquires a note issued by the purchaser under a conditional sales agreement, the note will be included in the party's investment allowance. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Brief discussion of application of s. 216 election where there is a non-resident partner in a partnership receiving rents from a MURB property. ...

3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Because an Alberta royalty tax credit is not included in a corporation's income for tax purposes, it also is not included in its safe income or safe income on hand. ...

7 September 1994 External T.I. 9415545- UNCLAIMED INTEREST & DIVIDENDS-- summary under Subsection 153(4) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(4) The reference to a "taxation year" and "year" in the preamble to s. 153(4) refers to the taxation year of the broker/security dealer and not to that of the unidentified individual (namely, a calendar year). ...

8 September 1994 Internal T.I. 9420937- HUSBAND & WIFE PARTNERSHIP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Before discussing the case law in the context of a dispute, RC stated that "in general, an acceptable partnership requires an investment by each partner, a written partnership agreement and proper notices to creditors and financial institutions concerning the existence of a partnership". ...

13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Discussion of the application of Part I.3 to loans to and from corporate partnerships, loans between partnerships and the impact of equity-based accounting for partnership interests. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) An RRSP that writes naked call options would be considered to be carrying on a business. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(9) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(9) It is the Departmental practice not to apply the provisions of s. 146(9) to an annuitant where an RRSP has written a covered call option and the holder of the covered call option in fact exercises her right to purchase under the option. ...