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Item 21: We suggest deleting "copyrights" in this item since subsection 212(5) refers specifically only to the right in or to the use of motion picture film or videotape and other means of reproduction for use in connection with television. ...

In this connection we refer you to Interpretation Bulletin IT-126R dated February 3, 1975 which discusses the winding-up or dissolution of taxable Canadian corporations in Paragraphs 3 to 7 inclusive. ...

The tax implications under such an arrangement are much different from those associated with retiring allowances, Consequently, we are not prepared to respond definitively to questions raised in connection with a portion of such an arrangement without examining the entire settlement document. ...

Convention will operate to exempt from tax awards of damages or payments pursuant to out of court settlements made in connection with the wrongful misappropriation of copyrights, since both provisions refer to payments made pursuant to the terms of consensual agreements. ...

While the issue is always a question of fact it is our view that the services performed as described above by FA for CCPC-II would not be services performed in connection with the purchase or sale of goods and therefore those services would be considered to be services for the purposes of paragraph 95(2)(b) of the Act. ...

4 December 1989 Income Tax Severed Letter 5-9089- Clarification of the retirement compensation arrangement provisions Unedited CRA Tags none Dear Sirs: This is in reply to your letter of November 15, 1989 wherein you requested clarification as to whether or not the retirement compensation arrangement ("RCA") provisions of the Income Tax Act (the "Act") XXX The RCA provisions generally apply when any "contributions" (payments) are made to another person, including a bank, trust company or other investment dealer, in connection with the payment of retiring benefits. ...

Generally, a RCA is an arrangement under which an employer makes contributions to a Custodian in connection with benefits that are to be, or may be, received on retirement or loss of employment. ...

We anticipate that it is unlikely that any shareholder benefit associated with a loan from a non-resident corporation to a non-resident individual that is not related to any other item of income that has a source in Canada or to any connection that either of the parties has in Canada would have a source in Canada. ...

In this connection, we draw your attention to paragraphs 3 and 12 of that Bulletin concerning property designated for a year after 1981 by a related person, such as your spouse or child, and land in excess of 1/2 hectare. ...

In connection with your concern, you have indicated that since interest earned on overpayment of tax must be included in income, interest charged on income taxes should be deductible. ...