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Robin Maley for Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ENDNOTES 1 This theme is reiterated in paragraph 2 of IT-128R ["...In this connection it is important to note that in computing the income of a partnership, subsection 96(1) and Regulations 1102(1a) require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"], and paragraph 15 of IT-285R2 ["It should be noted that, in calculating the income of a partnership, subsection 96(1) of the Act and subsection 1102(1a) of the Regulations require that partnership property (including depreciable property) be accounted for as if it were owned at the partnership level"]. ...

" As indicated in paragraph 15 of IT-120R6, generally the use of land in excess of 1/2 hectare in connection with a particular lifestyle (such as country living) does not mean that the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...

October 25, 2017 XXXXXXXXXX Income Tax Rulings Directorate Large File Case Auditor International Division XXXXXXXXXX John Meek 2016-065817 Application of Regulation 5900(3) and subparagraph 93.1(2)(d)(i) Dear XXXXXXXXXX, This letter is in response to a memorandum dated July 15, 2016 in which you raised questions in connection with the interaction of subsection 5900(3) of the Income Tax Regulations (the “Regulations”) and subparagraph 93.1(2)(d)(i) of the Income Tax Act (the “Act”). ...

Also, the financial compensation sought for the Indians is not entirely (if at all) for reserve lands but is for lands that were used by Indians; and thus there is even less of a connection to reserves. ...

This is evident from the various dictionary definitions of the word 'royalty' when used in connection with a sum payable. ...

November 4, 1997 Quebec Tax Services Office Resource Industries Richard Cloutier Section Forestry and Mining Specialist Peter Lee 957-8977 972582 Depreciable Property/Resource Expenses Further to our informal response to you by telephone, this is in reply to your request for our opinion in respect of the transitional rules in connection with the recent amendment to the definitions of Canadian exploration expense ("CEE") and Canadian development expense ("CDE") that was intended to clarify that depreciable property is not to be included in resource pools. ...

(d)requiring any class of persons to make information returns respecting any class of information required in connection with assessments under this Act;" "204.(1) Every person having the control of, or receiving income, gains or profits in a fiduciary capacity, or in a capacity analogous to a fiduciary capacity, shall make a return in prescribed form in respect thereof. ...

The foregoing should be of assistance to you in solving this dispute and other disputes involving the connection of a status Indian's income to a reserve. for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch ...

In connection with acquiring ownership to computer software, in our view, software is owned by the creator of the software or by a person who acquires the software in an outright sale. ...

Examples include paragraph 20(1)(aa): amounts paid for landscaping of grounds, paragraph 20(1)(cc): amounts paid for expenses of representation, paragraph 20(1)(dd): amounts paid for site investigation, and paragraph 20(1)(ee): amounts paid for utility service connections. ...