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8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. Paragraph l25.l(3)(a) of the Act defines M & P profit by reference to rules prescribed by regulation i.e. section 5200 and following of the Income Tax Regulations ("Regulations"). ...

4 December 1989 Ministerial Letter 73828A F- Integrated Sawmill & Pulpmill Subsection 125.1(1)- M & P Deduction Unedited CRA Tags 125.1(1), 5202   December 4, 1989 E.H. ... In the Webster's New Collegiate Dictionary, "handling" is defined as follows:      "a process by which something is handled in a commercial transaction, especially the packaging and shipping of an abject or material (as to a consumer)... ... Conclusion 24(1) DirectorBilingual Services & ResourceIndustries DivisionRulings Directorate ...