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.' " Further support of this line of reasoning is found in the reasons for judgement by Justice Pratte of the Federal Court of Appeal in The Minister of National Revenue v. ... Ltd., [[1974] C.T.C. 63] 76 DTC 6083, where he said at page 6083; "... ...

Walker & Co. Ltd. v. I.R.C. [1920] 3 K.B. 648]. In more recent rulings, cap interest rates based on an effective overall yield to maturity of 13.5% per annum and a flat 12% per annum were accepted at the outset of the financings as reasonable limits. ... " [at p.6184] CURRENT POSITION AND OUTSTANDING ISSUES To date, to our knowledge, there have been no favourable rulings granted by the Department in respect of participation payments under paragraph 20(1)(e) of the Act. ...

Taylor wrote "... I do not agree with counsel for the respondent that only costs incurred while the automobile is in motion are qualified for deduction as travelling expenses.... ... During the course of the Commons debate on Bill C-139 (Commons Debates March 10, 1983 p. 23670) the Government was specifically asked to define operating costs to which the response was: "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road. ...

As per paragraph 2 of IT-172R "... where an individual has income from non-business (e.g., property held to earn investment income) he... is not subject to the above capital cost allowance restriction (i.e. ... Page 18 & 19- Capital Cost Allowance- Amount Claimable The Department of Finance uses the phrase "the half-year rule" rather than the "one-half year rule" used in the fifth line on page 18. ...

B 1 common share 1 common share FMV = $1,000 FMV = $1,000 OPCO In the above example, Opco issues another share to Mrs. ... Round Table- Federal Taxation system 33.25 Answer by the Department of Revenue The Department has appealed Fortin & Moreau to the Federal Court-Trial Division. ... However, the exception does not apply to buildings including a permanent R & D infrastructure. ...

PRINCIPAL ISSUES: % ownership and amount being financed by DPS. POSITION: Give rulings. REASONS: Only % holding of debt being refinanced. XXXXXXXXXX XXXXXXXXXX 960884 XXXXXXXXXX Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Dear Sirs: Re: XXXXXXXXXX We are writing in response to your letter dated XXXXXXXXXX wherein you requested an advance income ruling on behalf of the above-noted taxpayers. ...

The definition of "cumulative gains limit" and the relevant portion of the "annual gains limit" read as follows: ""cumulative gains limit" of an individual at the end of a taxation year means the amount, if any, by which (a) the total of all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 for A in the definition "annual gains limit", or (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (a) of the definition "annual gains limit" as it read in its application to those years exceeds the total of (b) all amounts each of which is (i) the amount determined in respect of the individual for the year or a preceding taxation year ending after 1987 under paragraph (a) or (b) of the description of B in the definition "annual gains limit", (ii) the amount determined in respect of the individual for a preceding taxation year ending after 1984 and before 1988 under paragraph (b) or (c) of the definition "annual gains limit" as it read in its application to those years, or (iii) an amount deducted under paragraph 3(e) by the individual for the individual's 1985 taxation year, (c) all amounts deducted under this section in computing the individual's taxable income for a preceding taxation year, and (d) the individual's cumulative net investment loss at the end of the year;" The description of "B" in the formula A- B found in the definition of "annual gains limit" reads in part, as follows: "B is the total of (a) the amount, if any, by which (i) the individual's net capital losses for other taxation years deducted under paragraph 111(1)(b) in computing the individual's taxable income for the year exceeds (ii) the amount, if any, by which the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses exceeds the amount determined for A in respect of the individual for the year, and b) all of the individual's allowable business investment losses for the year; " (emphasis added is ours) Note that the definitions of "annual gains limit" and "cumulative gains limit" as they read prior to the 1993 amendments would yield the same result provided that none of the gains or losses in question relate to non-qualifying real property. ...

Harding A/Manager, Policy & Technical Services 957-8953 Trust Accounts Division Attention: Lloyd MacKay 2000-001003 Retirement Compensation Arrangements ("RCAs") This is in reply to your memorandum of February 23, 2000, in which you asked us to respond to comments received by you with respect to our memorandum to you dated January 17, 2000, (our file 1999-001524). ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch- 1-... ...

Government Assistance Issue The issues are twofold and relate to the position taken in our file # 9809735: 1. whether subsection 127(18) of the Act applies to net government assistance against the SR&ED qualified expenditures only where the government assistance is provided with respect to the construction of a building which will be used primarily for SR&ED, or whether it may also apply where the building will be dedicated primarily to manufacturing but in which substantial SR&ED will be performed, and 2. where the assistance (or a large portion thereof) is received and the building is constructed prior to the commencement of the SR&ED, whether the assistance which can be attributed to the SR&ED is to be netted in its entirety against the SR&ED qualified expenditures in the year such expenditures are first incurred, even if the result is a negative pool balance. ...