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Vance Sider Chief Foreign & Small Business Section Revenue Canada, Taxation 3rd Floor 88 Metcalfe Street Ottawa, Ontario KlA 0L8 Dear Mr. ...

& 3. L'alinéa 12(1)b) de la Loi stipule que toute somme recevable par un contribuable au titre de la vente de biens ou de la fourniture de services au cours de l'année, dans le cadre de l'exploitation de son entreprise, doit être incluse dans le calcul de son revenu tiré d'une entreprise. ...

En effet, l'alinéa 69(1)b) se lit comme suit: "... lorsqu'un contribuable a disposé d'un bien en faveur d'une personne avec laquelle il avait un lien de dépendance... ...

" While it is difficult to impugn this conclusion by reference to the provisions of Regulation 1200 it is obviously inconsistent with the legislative intent of the definition of oil and gas well equipment in regulation 1104 which includes "... equipment... to be used in a gas or oil field in the production therefrom of natural gas or crude oil... ...

Chief Financial Institutions Section Bilingual Services & Finance Division Corporate Rulings Directorate ...

Superannuation benefits & R.R.S.P. monthly payments Paragraph 1 of Article XVIII permits Canada to impose a tax on pension benefits arising in Canada and paid to a resident of Belgium. ...

The Technical Notes released by the Department of Finance in November of 1985 indicated that the provisions of former subsection 84(8) of the Act were "... repealed, as a consequence of the introduction of the new lifetime capital gain exemption, so that dividend treatment will apply. ...

Harris Appeals & Referrals Division 995-1723 ATTENTION P. Bush RE: 1979 Notice of Objection This is in response to your memorandum dated December 7, 1982 regarding XXXX Notice of Objection relating to the inclusion of storage (lay-away) sales in its income for the 1979 taxation year. ...

., would be precluded from deducting the moving expenses by subparagraph 62(1)(a)(i) of the Act. (2) & (3) the individual in these situations would not be disqualified for a housing loan provided that he was able to establish that he was ordinarily employed in Canada and was entitled to a deduction under section 62 of the Act. (4) Assuring that this situation refers to a loan made to an individual at the time when he was both resident and employed outside Canada, the loan would not qualify as a housing loan as defined by paragraph 80.4(2) (b) of the Act unless such a loan was made to enable or assist him to acquire a dwelling for his habitation if the acquisition of that dwelling was made in the course of a change in his residence from a place outside of Canada to a place within Canada. ...

In contrast, the response to the direct request to define "operating costs" as reported in the Commons Debates of March 10. 1983 was "... this includes gasoline, repairs, insurance and other charges that would be applied against the vehicle to keep it on the road"; a statement which could be used to support the Department's position. ...