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In connection therewith you also submitted for our comments the following example: "A non-resident may have employment income earned in Canada, a loss from a business carried on in Canada, and income from a source outside Canada. ...

You have described the facts as follows; XXX In order to qualify for the OETC pursuant to section 122.3 of the Income Tax Act, an individual resident in Canada in a taxation year must be employed by a specified employer throughout any period of more than 6 consecutive months that commenced before the end of the year and that individual must perform all or substantially all of his employment duties in a country or countries outside of Canada in connection with a contract under which the specified employer carried on business in such a country. ...

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

" (iii) In connection with the statement that IT-178R2 will be amended, we understand that the Publications Division has not been informed of this adverse decision. ...

However, subsection 18(3.1) of the Act requires interest expense and other costs of borrowing money in connection with the construction of a building to be capitalized as part of the capital cost of the building or as part of the capital cost of the land, as the case may be. ...

In this regard we are unable to send you a copy of our memorandum which concerned the deductibility of legal and accounting expenses incurred in connection with the deemed dispositions provided for by Section 104 of the Income Tax Act. ...

SUBJECT: REALIZATION OF CAP,GAIN BY SINGLE-PURPOSE CORP SECTION: 15(1)] 5-921435 Charles Theriault (613) 957-8953 June 19, 1992 Dear Sirs: This is in reply to your letter dated May 6, 1992 in which you requested our confirmation that the realization of a capital gain by a single-purpose corporation in connection with the disposition of personal-use property held by the corporation for the sole shareholder would cause the Department to assess a shareholder benefit to its shareholder for the use of the corporate-owned property pursuant to subsection 15(1) of the Income Tax Act. ...

A and B can make an election under subsection 216(1) of the Act in connection with the portion of the rental income earned by the ABC Partnership which is allocated to the AB Partnership and subsequently to Mr. ...

In connection with your request you have set out two excerpts from an article you enclosed which makes reference to a letter issued by this Department that was identified by control number 910482. ...

In this connection see subparagraph 1(b)of Interpretation, bulletin 1T-381R. ...