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7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

The taxpayer can direct that the funds be used at the Centre for:         A.   ... Of particular concern was the requirement in subsection 37(1)(a) of the Act that;     "... the taxpayer is entitled to exploit the results of such scientific research and experimental development... ... A Payer will be entitled to deduct from its income a contribution made in the year to a University pursuant to clause 37(1)(a)(ii)(B) of the Act, provided that the following conditions are met:          a)  the Payer carries on business in Canada in the taxation year;          b)  the funds are to be used by the University for SR&ED carried on in Canada;          c)  the SR&ED activity carried on by the University is related to the business of the Payer in the year the expenditure is made;          d)  the Payer completes and files Form T661, "Claim for Scientific Research and Experimental Development Expenditures"; and          e)  the Payer is entitled to exploit the results of the SR&ED. ...

7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus Unedited CRA Tags ITR 5902(2), 93(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 5902(2)(a) of the Regulations to the Act This is in reply to your letter wherein you requested clarification of the operation of section 5902 of the Regulations to the Income Tax Act (the "Act") in the following hypothetical circumstances: 1)     A corporation resident in Canada ("Canco") owns 95% of the common shares of a foreign affiliate ("FA1") which in turn owns 100% of the common shares of a second foreign affiliate ("FA2"). ... Both FA1 and FA2 have exempt surplus balances in respect of Canco. 2)     Canco disposes of its shares of FA1 to a third party and elects under subsection 93(1) of the Act to have a portion of the proceeds of disposition deemed to be a dividend received on those shares. ...

16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

9 October 2009 Roundtable, 2009-0330081C6 F- Sens de " année " au paragraphe 74.5(2) Unedited CRA Tags 74.5(2) Principales Questions: Quel sens faut-il donner à l'expression " année donnée " au paragraphe 74.5(2) pour établir le montant des intérêts payables? ... Michel Lambert (613) 957-8968 October 9, 2009 2009-033008 ENDNOTES 1 AGENCE DU REVENU DU CANADA, interprétation technique 912556, " Meaning of Particuliar Year ", 21 octobre 1991. 2 AGENCE DU REVENU DU CANADA, interprétation technique 2008-0274221I7 (E), Meaning of " year " in 74.5(2), 16 avril 2008. 3 Al. 249(1)b) L.I.R. 4 CANADA REVENUE AGENCY, technical interpretation 912556, "Meaning of Particular Year", October 21, 1991. 5 CANADA REVENUE AGENCY, technical interpretation 2008-0274221I7 (E), Meaning of "year" in 74.5(2), April 16, 2008. 6 Par. 249(1)(b) of the ITA ...

22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...

15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits Also released under document number 2003-00268270. ... January 15, 2004 ASSESSMENT & COLLECTIONS BRANCH HEADQUARTERS Individual Returns & Payment Processing Income Tax Rulings Directorate Directorate S. ...

7 August 1990 Income Tax Severed Letter- Cape Breton Investment Tax Credit Program — date of acquisition of property — foreign exchange rate Unedited CRA Tags none Subject: Cape Breton Investment Tax Credit (CBITC) Program_ Date of Acquisition of Property-Foreign Exchange Rate This is in reply to your Memorandum dated March 13, 1990 whereby you requested our opinion concerning the determination of the date of acquisition of certain equipment and the treatment of variations in exchange rates in respect of part of the purchase price paid before the date of acquisitions of the equipment. ... As stated in paragraph 6 of IT-50R: “... property can pass and acquisition take place only if the asset is in existence and, even then, only if it is a `specific asset', i.e. one that is capable of being identified as the object of the contract.” ...

6 August 1980 Income Tax Severed Letter RRRR15- Foreign affiliates — paragraph 95(1)(b) — foreign accrual property income LA 5600-1 Unedited CRA Tags 95(1)(b), 91(1) This is in response to your enquiry of July 22, 1980 concerning the amount that is to be used as the capital cost, when claiming capital cost allowance on property that was owned prior to 1972, in calculating foreign accrual property income as defined in paragraph 95(1)(b) of the Income Tax Act for purposes of subsection 91(1) of the Act. ...