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19 January 1994 Administrative Letter 9325936 F- 149.1(1)(a) Unedited CRA Tags 149.1(1) charitable organization, 149.1(1) charitable foundation January 19, 1994 Charities Division     Head Office Application Examination Section      Rulings DirectorateMr. Bryan McLean      (613) 957-8953A/Chief Attention:  Sandy Chartrand XXXXXXXXXX This is in reply to your memorandum of September 13, 1993 wherein you requested our views on the application for registration as a charity of XXXXXXXXXX particularly whether the unique manner in which the organization intends to raise funds disqualifies it from such registration. ...

Passive Income- Partnership and Co-Own Unedited CRA Tags 125   911476   A.Y. ... To illustrate, you have provided us the following hypothetical facts:-      Partnership AB, a Canadian partnership, has two partners, A and B.-      Partners A and B deal with each other at arm's length.-     Pursuant to the partnership agreement partner A receives a minimum return on capital invested prior to the allocation of income or loss of partnership AB to the individual partners. ... Yours truly, for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental     Affairs Branch ...

17 July 1992 Administrative Letter 9219946 F- Commodity Based Loans Unedited CRA Tags 54 disposition   921994   F. Francis   957-8971 July 17, 1992 Audit DirectorateRulings DirectorateGeneral Audit ServicesFinancial Industries Division Attention:  M. ...

27 January 1992 Administrative Letter 9200306 F- Hoedel Auto Benefit For Dog Handler Unedited CRA Tags 6(2), 8(1)(h), 8(1)(h.1) January 27, 1992 General Audit Services     Personal and General Technical Support Division      Section K.R. Warren, Acting Director     A. Humenuk (613)957-2134 Attention: Ron B. ...

A)     Deductibility of Contributions      We cannot agree with your conclusion that contributions by members would be deductible to them. ... B)     Taxability of the 24(1)      It is your view that.. if the organization is considered an extension of the 24(1) it may qualify for exempt status under paragraph 149(1)(e) of the Act. ... A determination can only be made based on the facts of each case and such a determination cannot be made in advance of, or during a particular year, but only after the end of the year.       ...

Paragraph 5 (i)       We suggest that the first sentence be deleted and replaced with:      Opco derives its income from a small manufacturing business. (ii)      We suggest that you delete the sentence "The Building is Opco's only asset of Class 3 of Schedule II to the Income Tax Regulations".       ... Paragraph 6 (i)      We suggest that the words "distributor of electrical appliances" be changed to "distributor of certain products". ...

In order to qualify in Class 29/39, assets must be used in M & P.  ... In our opinion, based on the definitions contained in the Regional Development Incentives Regulations, 1974, 24(1) would not be considered to be M & P and fits the definition of an initial processing operation in a resource based industry. c)     In our opinion, 24(1) does not constitute M & P for purposes of the M & P deduction.  ... As such, the transportation would not be considered to be M & P in determining whether the taxpayer's activities were primarily M & P for purposes of paragraph 5201(a) of the Regulations relating to the "Small Manufacturers' Rule", assuming the taxpayer could show that it was not restricted by paragraph 5201(c) of the Regulations. 3)     24(1) a)     In our opinion, 24(1) constitutes M & P for the purposes of Class 29/39.  ...

Paragraph 18(1)(a) is discussed in IT-487. €     Section 67 provides that the outlay or expense is deductible to the extent it is reasonable in the circumstances. €     Outlays and expenses are only deductible after the business has commenced. ... Please refer to paragraphs 6 and 7 of IT-364. €     Paragraph 18(1)(b) denies a deduction for capital outlays. ... Such capital outlays would be capitalized and included in the appropriate Class in Schedule II of the Regulations. €     Paragraph 18(1)(h) of the Act denies a deduction for personal or living expenses. €     Subsection 67.1(1) of the Act limits the deduction to 80% respecting the consumption of food or beverages or the enjoyment of entertainment. ...

26 January 1994 Administrative Letter 9332406 F- Non-Resident Trusts and 21-Year Rule Unedited CRA Tags 104(4), 115(1)(b), 115(1)(a)(iii), 104(5.3) International Tax Programs Directorate       Rulings Directorate      957-8953 Attention:  Mr. ...

8 May 1992 Administrative Letter 9209536 F- Short Form Vertical Amalgamation Unedited CRA Tags 87(1.1), 88   920953   D. Watson   (613)957-2121 May 8, 1992 W.S. HumeT2 and T3 Programs DivisionRulings DirectorateT2 Programs Division Attention:     C. ...