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Oulton (613) 995-1787 April 17, 1984 XXXX This is in reply to your letter dated January 20, 1984 in connection with the application of paragraphs 94(1)(c) and (d) to a non-resident trust and to a beneficiary which is a person resident in Canada. ...

Please review Exhibit VI, item FB9119, where the taxpayer claims that a mixing operation must take place in the tanks to bring the product into a saleable state. c) Pipeline may qualify for Class 29, when it is an integral part of M & P activity within a manufacturing plant. d) Sewers and drains (as being part of a building) used in connection with the M & P operations qualify for class 29. ...

In connection with the rollover, the individual has requested that the auditors for Opco determine the eligibility of the individual's shares as qualified small business corporation shares in accordance with the terms of subsection 110.6(1). ...

We are writing in reply to your memorandum of April 13, 1988, wherein you requested confirmation of our policy concerning the issue of the deductibility for income tax purposes of interest expense incurred in connection with an-overpayment of incentives under the Alberta Petroleum Incentive Program ("APIP") in circumstances described by you as follows: Facts XXXX As you have pointed out, we have considered this issue before in the context of a repayment of incentives pursuant to the Petroleum Incentives Program Act (the "PIP Act") and Regulations promulgated thereunder. ...

In this connection, the most convenient time for determining the amount loaned to a shareholder is the corporation's year end, when the accounts for the corporation are verified and where significant adjustments to the loan account are moreover most likely to occur. ...

Our concerns in this area lie with the valuation problems which might arise in connection with shares to be issued in the future. ...

Thirdly, it may be of interest to note in connection with your conclusions that if a subsection 84(3) dividend is caught by subsection 55(2), the whole amount is caught and not just the portion of the gain attributable to something other than income earned or realized before 1972. ...

A as a separate inducement in connection with his employment and not in lieu of salary or other remuneration. ...

In connection with the foregoing, the third anniversary of the investment contract is computed with reference to the date the employee agrees to participate in the plan. ...

While a corporation that does not have and has never had any connection with Canada may not be subject to the requirement under subsection 150(l) to file a return, generally corporations and in particular all corporations resident in Canada and all non-resident corporations that carried on business in Canada, disposed of taxable Canadian property, had income of the kind referred to in section 115 of the Income Tax Act, or had a permanent establishment in Canada must comply with subsection 150(l). ...