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Peters in his comments which concluded that: (1) "Cutting and removing merchantable timber from a timber limit" includes all activities up to and including operating a central gathering point, including a dryland sort, but does not include activities beyond that point. (2) An asset may be located off the timber limit and still qualify for Class 10(n) or Class 15, provided that it is used in activities prior to or at a "central gathering point". (3) Perpetual yield forest management does not disqualify immovable assets from Classes 10(n) and 15. (4) Immovable assets are not disqualified from Class 10(n) or 15 because they service more than one timber limit. (5) (a) Logs are "finished goods" of logging, & (b) Storing and shipping logs does not commence until the logs are packed or "packaged" in the manner in which they will be shipped, and (6) (c) Assets used past the point where logs are packed or packaged do not earn investment tax credits because they are used to store or ship finished goods. (7) We should be concerned that perpetual yield forest management results in long useful economic lives of immovable forest assets but the high rates of capital cost allowance seem to indicate these assets were expected to have much shorter useful economic lives. ... In our view, point (a) is the only point which need be accepted to reach this conclusion. (4) Immovable assets are not disqualified from Class 10(n) or 15 if they service more than one timber limit: We agree as has been conveyed to you in the response to our file 7-2622 dated October 6, 1988. (5) (a) Logs are "finished goods" of logging: & (6) It is our view that logs would not be considered "finished goods" within the context of the use of the term in paragraph 127(11)(b) of the Act (reference our memorandum to you on this subject, dated October 20, 1988). ...

In order for a taxpayer to claim medical expenses under this subparagraph the payments must be made "... for the full-time care in a nursing home of, a person who is the taxpayer, his spouse or any such dependent and who has a severe and prolonged mental or physical impairment that is certified as such in prescribed form by a medical doctor... ... A similar claim under subparagraph 110(1)(c)(v) of the Act, requires a taxpayer to have expenses "... for the full-time care in a nursing home of the taxpayer, his spouse or any such dependent, who has been certified by a qualified medical practitioner to be a person who, by reason of lack of normal mental capacity, is and in the foreseeable future will continue to be dependent on others for his personal needs and care,". ...

Fast & Sons Distributors Ltd., 86 DTC 6106. They also refer to the comments and illustrative examples given by CCH Limited at paragraph 28,366 of the Canadian Tax Reporter and by MacDonald and Cronkright on page 48,038 of Income Taxation in Canada. ... However, the comments by both CCH Limited and by MacDonald & Cronkright provide clarification. ...

Our position remains as stated in answer to question 18 of the Thirty-Seventh Canadian Tax Foundation Conference, 1985 Revenue Canada Round Table Questions & Answers (a copy is enclosed for your convenience). ... Yours truly, for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch Question # 18 1) What is Revenue Canada's position regarding management service companies and management service fees? ...

Une expression autre que celle de " résidence temporaire " devrait être utilisée dans le Communiqué-décision puisque celle-ci peut laisser croire qu'une personne qui séjourne dans une région visée peut être admissible à la déduction prévue à l'article 110.7 de la 000025/cont'd Loi. ...

La position du Ministère concernant la liquidation d'une organisation sans but lucratif est exprimée dans le bulletin d'interprétation IT-409 du 27 février 1978 (le " IT-409 "). ...

—Change in Facts to Advance Income Tax Ruling #2006-018810 [] (the “Ruling”) This is in reply to your request for a minor amendment to the Ruling that was issued to the above-noted taxpayer on XXXXXXXXXX, 2006. ...

ADM'S OFFICE (2) 97-1690D & RETURN TO 15TH FLOOR, ALBION TOWER 97-07553M February 10, 1998 XXXXXXXXXX Dear XXXXXXXXXX: I am writing in response to your letter of December 4, 1997, to Mr. ...

December 23, 1993 London District Office Head Office Business Enquiries Rulings Directorate (613) 957-8953 Attention: Morris Zambon / Katherine Kiar 930768 Paragraph 149(1)(t) and Subsections 124(1) and 125(1) This is in reply to your memorandum of March 17, 1993, concerning the anomaly resulting when a taxpayer entitled to tax exemption under paragraph 149(1)(t) claims the 10% tax abatement under subsection 124(1). ...

18 December 1992 Income Tax Severed Letter 922988A F- Qualified Farm Property- Restricted Farm Losses Unedited CRA Tags 31(1), 110.6(1) qualified farm property   XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  XXXXXXXXXX This is in reply to your letter of September 14, 1992 wherein you request an advance Income Tax Ruling concerning section 85 of the Income Tax Act (the ("Act") and enhanced capital gains exemption. ...