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The query raised in your letter relates to the bracketed exception in the definition of specified investment business in paragraph 125(7)(e) in respect of “... a business (other than... a business of leasing property other than real property) the principal purpose of which is to derive income from property...” ...

That definition specifically requires that the policy must be one under which "... no amount is payable to a person other than the group policyholder as a result of contributions made to or under the policy by the employer of the taxpayer before the death or disability of the taxpayer". ...

7 June 1991 Income Tax Severed Letter- Meaning of \"Benevolent or Fraternal Benefit Society or Order\" Unedited CRA Tags 149, 138 Subject: XXX This is in reply to your memorandum of April 15, 1991, concerning the tax status of the XXX under subsections 149(1) & (3) of the Act. ...

7 October 1991 Income Tax Severed Letter- Reporting on the Acquisition and Disposition of Securities Unedited CRA Tags Reg. 230 Dear Sirs: Re: Reporting on the Acquisition & Disposition of Securities We are replying to your letter of July 19, 1991 concerning the obligations imposed by Regulation 230 of the Income Tax Act on traders, dealers, agents and nominees who buy or sell securities on behalf of others. ...

For example, if the ACB of the partnership interest to a predecessor is negative $100, so that the cost to Amalco becomes negative $100 by virtue of paragraph 87(2)(e), then subsection 40(3) would deem there to be a gain to Amalco in the amount of $100, being the amount by which:(a) all subsection 53(2) deductions from Amalco's ACB $ 0 exceeds (b) the aggregate of (i) the cost to Amalco $-100 (ii) all subsection 53(1) addition to Amalco's ACB)-100 $100 This conclusion appears to be supported by the decision in Canterra Energy Ltd v. ...

7 February 1991 Income Tax Severed Letter- Nil Assessments Unedited CRA Tags 152(1.1), (4), Information Circular 75-7R3 Subject: Nil assessments (You file HAV 8621-4 & HAV 4568-1) This is in reply to your memorandum dated January 14, 1991 in which you requested our comments on the applicability of subsection 152(4) of the Income Tax Act (the “Act”) to nil assessments. ...

As stated in paragraph 1 of Interpretation Bulletin IT-85R2, in order for the Trust to qualify as a health & welfare trust, the benefit programs funded through the Trust must be restricted to one or more of the following plans: a) a private health services plan (PHSP), b) a group term life insurance policy, or c) a group sickness or accident insurance plan. ...

In order for equipment to qualify as pollution control equipment under class 24 or 27 of Schedule II of the Regulations, one of the many requirements contained in either of those two classes which must be satisfied, is that the equipment was acquired "... primarily for the purpose of preventing, reducing, or eliminating pollution... ...

Ken & Ray's Collins Bay Supermarket Ltd. [[1975] C.T.C. 504] 75 DTC 5346 (FCTD). ...

Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...