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25 May 1992 Income Tax Severed Letter 9212398- M & P Credits- Nowsco and Halliburton Cases ISSUE SHEET Question 30- Manufacturing and Processing Profits Tax Credits (1991 Canadian Tax Foundation Roundtable) Issue The question asked for Revenue Canada's assessing guidelines for M&P credits in light of the Federal Court of Appeal decisions in Nowsco, 90 DTC 6312 and Halliburton, 90 DTC 6320. ... Tax Conference in September, 1991 and is consistent with the Appeals Decisions # 86-14R and # 90-30, both dated August 17, 1990, pertaining to the Halliburton and Nowsco cases, respectively....cont... ... Prepared by:John Chan May 25, 1992 # 5-921239 Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information 1 ...

30 March 1988 Income Tax Severed Letter 5-5293- [] Unedited CRA Tags 95(2)(i) Dear Sirs: We are writing in response to your letter dated December 29, 1987 in which you have asked for the Department's views on the application of paragraph 95(2)(i) to the following hypothetical situation. ... Provided there is clear evidence, at the time of the disposition of the excluded property, that arrangenents are being made for the repayment (with due dispatch) of the "related debt", it is our view that the fact that the actual repayment of the debt occurs after the disposition of the excluded property would not, in and by itself, result it the debt not being considered "... related at all times... ". However if it was determined that other factors (such as cash flow problems, or unfavourable prevailing interest or exchange rates) contributed to the delay in repayment, it is likely that the provisions of paragraph 95(2)(i) would not apply on the repayment of the debt. ...

5 March 1986 Income Tax Severed Letter 6013-2- [Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures] Unedited CRA Tags 67, 245(1), 37(1), 194(2) Decision Summary Scientific Research Section Subject: Legal opinion dated November 15, 1985 Unreasonable R & D Expenditures Reference: 67, 245(1), 37(1) and 194(2) Issue: Do 67 and 245(1) apply to 37(1)(a) and 37(1)(b) amounts claimed as a Part VIII refund under 194(2)? ... Decision: To accept the legal opinion that 67 and 245(1) apply to R & D expenditures claimed as a Part VIII refund as defined in 194(2). ...

12 December 1991 Income Tax Severed Letter 9131378 F- Deferred Salary Leave Plan for Teachers — Six Months Unedited CRA Tags ITR 6801 MINISTER/DM'S OFFICE    YS:  91-8538TCENTRAL RECORDSAUTHORSECTION CHIEFDISTRICT OFFICESUBJECT OR CORPORATE CASE FILERETURN TO RULINGS, ROOM 303, METCALFE BLDG Dear 19(1) I am writing in response to your letter of  November 1, 1991, regarding the representations you have  received from your constituent,  expressed concern about the Department's interpretation of Regulation 6801 of the Income Tax Act as it affects teachers wishing to participate in deferred salary leave plans.  ... I trust my comments will assist you in your reply to your constituent.                           Yours sincerely,                           Otto Jelinek 913137 ...

17 December 1986 Income Tax Severed Letter 5-2409- [] XXXX G. Kauppinen (613) 957-3495 December 17, 1986 Dear Sirs: This is in reply to your letter dated October 31, 1986 wherein you requested our opinion with respect to subsection 73(5) of the Income Tax Act ("Act") assuming the following: 1. ... The conditions outlined in subparagraphs-12(a), (b) and (c) of Interpretation Bulletin 486 (" IT-486 ") are satisfied. ...

20 October 1989 Income Tax Severed Letter AC80320- D & B Oilfield Contracting Ltd.- Adverse Decision E. ... Angus 8-0320 RE: D & B OILFIELD CONTRACTING LTD. ADVERSE DECISION- TAX COURT OF CANADA This is in reply to the memorandum of September 20, 1989. ...

19 April 1990 Income Tax Severed Letter 900259- Self-directed RRSP — Mortgage as Qualified Investment Unedited CRA Tags 146(1)(g), Reg. 4900(1)(j), 4900(4) This is in reply to your letter of March 27, 1990 concerning the above-mentioned subject. ... As outlined in paragraph 8 of Interpretation Bulletin IT-320R, (special Release dated May 25, 1984) other requirements to be met include • the amount of the mortgage interest rate and other terms must reflect normal commercial practice, and • the mortgage must be administered as if it were on property owned by a stranger. ...

7 June 1990 Income Tax Severed Letter AC74847- Oil & Gas Steering Committee Unedited CRA Tags none Special Audits Division Resource Industries E.H. ... Gauvreau 957-8953 7- 4847 Oil & Gas Steering Committee Meeting Minutes We are writing in reply to your request of March 28, 1990 to determine whether the above-captioned minutes contain errors or omissions. ...

18 March 1983 Income Tax Severed Letter 5-0057- [(1) Gross & Net Royalty Trust/(2) Reporting of Resource Income and Allowances] DATE: March 18, 1983 TO- Corporate Rulings Division FROM- Audit Programs Division Estate and Trust Group T. ... Carsley RE: (1) Gross & Net Royalty Trust (2) Reporting of Resource Income and Allowances We refer to the attached memoranda at March 8 and 15 concerning resource income and resource allowance. ...

24 January 1990 Income Tax Severed Letter ACC8926- Canada-Portugal Reciprocal Air & Shipping Exemption B. Fioravanti (613) 957-2073 HBW 4290-1 19(1) January 24, 1990 Dear 19(1) Re: Canada- Portugal- Reciprocal Air & Shipping Exemption Your letter of January 9 together with enclosures has been referred to the attention of C. ...