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We would note that comments in the above Technical Guide concerning eligible / ineligible assets of "systems" or "enhanced combined cycle systems" qualifying under paragraph (c) to Class 43.1, indicate that not all assets associated with Qualifying Equipment are considered eligible assets, i.e., not all of such assets should be considered "ancillary to" such equipment for purposes of subparagraph (a)(iv) to Class 43.1. ...

Subsection 98(3) of the Act states in part: "... a Canadian partnership has ceased to exist and all the partnership property has been distributed to persons who were members of the partnership immediately before that time so that immediately after that time each such person has, in each such property, an undivided interest that, when expressed as a percentage (in this subsection referred to as that person's "percentage") of all undivided interests in the property, is equal to the person's undivided interest, when so expressed, in each other such property... ...

If you have further interpretative issues regarding residence status determinations, or if you have comments or questions with respect to IT-221R3, please write to the International & Trusts Division of this Directorate. ...

However, in response to question # 20 at the 1994 Association de Planification fiscale et financière (APFF) Conference Round Table, CCRA explained that: Interpretation Bulletin IT-114, issued in 1973, was cancelled in full because it did not reflect significant changes to the Income Tax Act and was no longer a useful guide to the taxation of discounts, premiums and bonuses relating to a multiplicity of financial products that have changed considerably. ...

Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch c.c. ...

If you have further interpretative issues regarding residence status determinations, or if you have comments or questions with respect to IT-221R3, please write to the International & Trusts Division of this Directorate. ...

Yours truly, Olli Laurikainen for Director International & Trusts Division Income Tax Rulings Directorate ...

This case was validated by the Supreme Court of Canada in M. v H ([1999] 2 S.C.R. 3, 46 R.F.L. (4th) 32) where the following was stated at paragraphs 59 and 60: " Molodowich v Penttinen (1980), 17 R.F.L. (2d) 376 (Ont. ...

Le robot fut acquis, soit en l'an 1999 soit en l'an 2000, à un prix de 7 000 $. ...

Income Tax Convention (the " Convention") applies to exclude the amount. ...