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4 March 1992 Income Tax Severed Letter 9123895 - Withholding tax on royalties (trademarks, designs, etc.)

We would agree that rules of instruction and other written material used in connection with such games will probably be considered as "literary work" and therefore subject to copyright. ...

25 September 1989 Income Tax Severed Letter 3-2674 - Advance income tax ruling—deferred salary leave plan

A ruling request must also contain a statement as to whether any of the issues involved are to the best of the taxpayer's knowledge being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection. ...

28 July 1987 Income Tax Severed Letter 5-3485 - Interpretation of the words “licence to use” found in the definition of “computer software” in subsection 1104(2) of the Income Tax Regulations

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. ...

13 February 1992 Income Tax Severed Letter 9119225 - Computer software royalties — “rentals”

Ltd. [[1980] C.T.C. 352] 80 D.T.C. 6272 ("Saint John Shipbuilding"), at 6275 where Judge Thurlow states that "The word "rental" is not a familiar one to use in connection with property rights of the kinds enumerated but I see no reason to think that when used in reference thereto it would connote characteristics different from those it has in its more familiar use in relation to tangible property. ...

9 September 1987 Income Tax Severed Letter 5-3865 - Technical Interpretation on meaning of “amount deposited”

In connection with this question1 you refer to the quotation by the Supreme Court of Canada in Re Alberta Legislation, [1938] 2 D.L.R. 81 at 99, from Macleod, Theory of Credit at pp. 368-9, as follows: "... it is the entry to the credit of the customer which, in the technical language of modern banking is termed a Deposit... ...

31 May 1989 Income Tax Severed Letter 5-8011 - Meaning of the words “... where, in contemplation of and before the transfer, property has become property of the particular corporation ...” in the midamble of paragraph 55(3)(b)

It is not our view that an acquisition will necessarily be considered to have occurred in contemplation of a subsequent butterfly reorganization, merely because it is intended, at the time of the acquisition, to carry out the butterfly reorganization; instead, we consider that there must be some causal connection between the acquisition and the later reorganization. ...

2 January 1987 Income Tax Severed Letter 5-2683 - Liability to a non-resident lender incurred in purchasing the net assets of the lender—Canada-US treaty

The second sentence of Article XI(6) provides an exception to this rule are the following conditions are met: 1) The payor has a permanent establishment or fixed base in another State in connection with which the indebtedness was incurred which gave rise to the interest payments. 2) Such interest is borne by such permanent establishment or fixed base. ...

29 September 1988 Income Tax Severed Letter 7-2840 F - Meaning of term “Canadian risks” in subsection 95(3)

Accordingly, we would agree that a risk of a loss, such as lost earnings, that would be directly felt or suffered in Canada or by a Canadian resident would seem to have a sufficient connection with Canada to constitute a "Canadian risk". ...

7 July 1996 Income Tax Severed Letter 9619943 - Structured settlements

You have advised and you confirm, to the best of your knowledge, that none of the issues involved in this ruling request is being considered by a Tax Services office or a Tax Centre in connection with a tax return already filed and none of the issues is under objection. ...

7 July 1996 Income Tax Severed Letter 9613683 - Early repayment of debt, withholding tax on interest

To the best of your knowledge, none of the issues raised in the present request have been or are being considered by a District Taxation Office or Taxation Center in connection with a tax return already filed. ...

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