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8 September 1994 Internal T.I. 9420937- HUSBAND & WIFE PARTNERSHIP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Before discussing the case law in the context of a dispute, RC stated that "in general, an acceptable partnership requires an investment by each partner, a written partnership agreement and proper notices to creditors and financial institutions concerning the existence of a partnership". ...

13 October 1994 External T.I. 9413095- CORP.PARTNERSHIPS & PART I.3-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Discussion of the application of Part I.3 to loans to and from corporate partnerships, loans between partnerships and the impact of equity-based accounting for partnership interests. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(4) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4) An RRSP that writes naked call options would be considered to be carrying on a business. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(9) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(9) It is the Departmental practice not to apply the provisions of s. 146(9) to an annuitant where an RRSP has written a covered call option and the holder of the covered call option in fact exercises her right to purchase under the option. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) Index options are not qualified investments for an RRSP except in respect of the particular time, if any, when it can be clearly established that cash will be realized if the options are exercised at that time. ...

10 March 1995 External T.I. 9500835- QUALIFIED INVESTMENTS & FOREIGN PROPERTY-- summary under Paragraph 206(1)(h) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1)(h) Canadian government bonds denominated in a foreign currency are not foreign property. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium annuitant's payment of management fees was a contribution The payment of investment management fees of an RRSP by the annuitant will be treated (unlike the payment by the annuitant of administration fees) as the payment of a premium to the RRSP. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) Where funds inside an RRSP (or RRIF) are used to pay administration fees, no benefit or amount is received by the annuitant as a consequence thereof. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES-- summary under Subsection 146.3(2) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(2) Payment by an annuitant of the fees charged for the management of property of an RRIF would be prohibited by s. 146.3(2)(f) and would result in an inclusion in income of the annuitant equal to the fair market value of the RRIF property. ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146.3(11) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(11) Expenses relating to the administration or management of the property in an RRIF will result in an income inclusion to the annuitant pursuant to s. 146.3(11). ...