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Dodd Attention: XXXXXXXXXX February 22, 1996 Dear Sirs: Re: Adjusted Cost Base of Partnership Interest We are writing in connection with your letter dated February 13, 1996, requesting clarification of the Department's change in position, announced on July 28, 1995, in the publication Income Tax Technical News No. 5, regarding the adjusted cost base of a partnership interest. ...

in the course of duties in connection with the administration or enforcement of the Act; or 3.      ...

Although it would always be a question of fact whether the amounts described in paragraphs 181.2(3)(a), (b), (d) and (f) of the Act were used to acquire a particular property, we would expect that the taxpayer should be able to support a link or connection between the capital and the property. ...

15 February 1993 External T.I. 9334215 F- Travel Expenses- Rental Property Unedited CRA Tags 18(1)(h), 9(1) XXXXXXXXXX Dear Madam: RE:  Travel Expenses- Rental Property This is in reply to your letter of November 10, 1993 in which you asked us whether you are entitled to deduct vehicle expenses which you incur in connection with a rental property. ...

RULINGS DIRECTORATE CORRESPONDENCE SUMMARY DOCUMENT TYPE: Opinion Principal Issues: Whether interest is deductible on borrowed money used to repay an amount payable for property acquired for use in business Position TAKEN: yes Reasons FOR POSITION TAKEN: 20(3) deems the borrowed money to be used for the same purpose as the original debt LEGAL; FINANCE OPINION: JURISPRUDENCE: RCT PUBLICATIONS: HAA NUMBER: XXXXXXXXXX 940289 Attention: XXXXXXXXXX March 3, 1994 Dear Sirs: Re: Subsection 20(1)(c) of the Income Tax Act (the "Act") This is in reply to your letter of January 31, 1994, wherein you requested our opinion with respect to the deductibility of interest expense in a situation where a corporation borrows money to repay an interest-free shareholder loan which was originally incurred in connection with the purchase of a building. ...

In connection with these comments we would also refer you paragraph 42 of Interpretation Bulletin IT-522 "Vehicle and Other Travelling Expenses- Employees". ...

The cost of these tickets, which would either be sold at a higher price or held by the corporation in connection with the draw, would be a deductible business expense of the company. ...

In connection with these comments, we refer you to paragraphs 4 and 5 under the heading "References to Medical Professionals" in the enclosed Interpretation Bulletin IT-519R "Medical Expense and Disability Tax Credits and Attendant Care Expense Deductions" which has been enclosed. ...

In connection with a personal services business, we note that employment is not insurable and is not subject to Employment Insurance premiums when a corporation employs a person who controls more than 40% of the corporation's voting shares. ...

Since your situation dealt with prizes received by athletes in connection with their athletic endeavours, the reduction pursuant to subsection 56(3) is simply $500. ...