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6 June 1994 External T.I. 9337485- Partie XIII — Droit d'utilisation de logiciels information-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) The position of Revenue Canada that a payment for the use of, or the right to use, software in Canada is caught by s. 212(1)(d)(vi) applies even if the payment is made as a lump sum rather than periodically. ...

30 September 1994 Internal T.I. 9414527- BORROWINGS & EXCESS INSURANCE COLLATERAL-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Where the life insurance coverage under an assigned policy is $500,000 and the average balance owing under the borrowing is $200,000, the amount deductible under s. 20(1)(e.2) is limited to 40% of the lesser of the premiums payable and the net cost of pure insurance under the policy for the year. ...

23 July 1996 External T.I. 9612365- ARTICLE XI(4) & "INCOME ASSIMILATED TO INCOME"...-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 A payment by a credit union to a member, in respect of a share of capital stock, which is deemed to be interest by s. 137(4.1) of the Act will be considered to be interest for purposes of Article XII of the Canada-U.S. ...

23 November 1993 External T.I. 9322405 F- SR & ED-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Where a non-resident company makes charges in the form of technical fees, royalties or licence fees to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of SR&ED previously performed in Canada, this will not jeopardize the eligibility of the Canadian taxpayer for the ITC. ...

27 March 1994 Income Tax Severed Letter 9508671- LIFETIME CAPITAL GAINS EXEMPTION & PERSONAL TRUST-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) Because it is not possible for a deemed capital gain (in this instance, arising under s. 110.6(19)) to be income (or a capital gain) for trust purposes, a capital encroachment power and/or the issue of a promissory note would not be sufficient to make such a deemed gain payable for purposes of s. 104(24). ...

26 July 1995 External T.I. 9501585- court ordered partition & sale disposition-- summary under Subsection 44(1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1) Where as a result of the bankruptcy of one of the four co-tenants of rental properties, a court-appointed trustee receives court approval for severance, partition and sale of the property, the non-bankrupt co-tenants would be entitled to utilize s. 44(1) in respect of their proceeds (in this case, property interests in other co-owned buildings). ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) "For purposes of Part I.3, and with respect to leases, it is the department's position that it is the legal nature of the agreement that governs irrespective of the accounting treatment or nomenclature used to describe or characterize the related transaction(s). ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) The obligation of a purchaser under a conditional sales agreement generally will be included in its capital only where such obligation has been outstanding for more than 365 days, unless the obligation is evidenced by the issuance by it to the vendor of a note. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) A lease obligation reflected as an asset on the balance sheet of a lessor corporation is not eligible for an investment allowance as a loan or advance. ...

Between Sub. 13(21.2) & 88(1) of ITA-- summary under Subsection 13(21.2) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21.2) Where a subsidiary corporation has had s. 13(21.2) apply to a transfer of depreciable property to its parent corporation, and the subsidiary is then wound up under s. 88(1), ss. 88(1)(e.2) and 87(2)(g.3) will deem the parent corporation to be a continuation of the subsidiary corporation for the purposes of applying the rules in s. 13(21.2) to the parent corporation in respect of the denied terminal loss. ...