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XXXXXXXXXX XXXXXXXXXX Attention: XXXXXXXXXX Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your letter dated XXXXXXXXXX, wherein you requested advance income tax rulings on behalf of the XXXXXXXXXX and the partners thereof, in connection with the proposed transactions described below. ... The Partnership is not entitled and does not expect to be entitled to any form of government assistance in connection with the Project, and the Partnership is not entitled and does not expect to be entitled to any proceeds of disposition by way of an agreement or other arrangement under which it has a right, either absolutely or contingently, to dispose of any interest in its property. ... Provided (i) the terms of the Full Recourse Debt are as described above in paragraphs 28 and 30, and (ii) that, as of the date of this letter, the only statements and representations (as contemplated in subsection 237.1(1) of the Act at the definition of "tax shelter") proposed to be made in connection with the interests acquired in the Partnership after the date of this letter, or in connection with the Partnership's investment in the property relating to the XXXXXXXXXX after the date of this letter, are those in Schedule "B" neither the interests acquired in the Partnership after the date of this letter, nor the Partnership's investment in the property relating to the XXXXXXXXXX acquired after the date of this letter, will be a tax shelter within the meaning of subsection 237.1(1) of the Act. ...

There is clear authority from the courts that costs in connection with financing are expenditures on capital account unless the taxpayer is engaged in the business of lending money (Montreal Light, Heat & Power Consolidated v. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...

In connection with the above and some hypothetical facts you ask that we determine anniversary dates for four situations and in a related matter ask with respect to three scenarios, whether in our opinion the loan had been "materially altered" as that term is used in the coming into force provisions of subsection 12(4) in Bill C-28 (June 1989). ...

Our Comments In order for the partnership to be considered to be a tax shelter, one must regard "statements or representations made or proposed to be made in connection with the property," according to the definition of tax shelter in subsection 237.1(1).  ...

Thornley   (613) 957-2101 February 23, 1990 Dear Sirs: Re:  Non Profit Organizations ("NPO's") This is in reply to your letter of December 7, 1989 requesting our interpretation of a number of issues which have come to your attention in connection with NPO's. ...

At page 89 it further stated that the real question is whether or not there are any inter-connection, any interlacing, any inter-dependence, any unity at all embracing those two businesses. ...

Since "exempt loss" and "taxable loss" are only defined (in paragraphs 5907(1)(c) and 5907(1)(j) respectively) in connection with a foreign affiliate of a corporation, no amounts would be determined under those provisions in respect of a foreign affiliate of an individual. ...

In this capacity, she provides residential support, including room and board, to one mentally handicapped person contracted to the Association by the       24(1)       In connection with this situation, you have enclosed a document entitled "Terms of Agreement with Caregiver" (the Agreement) which indicates that the caregiver is an employee of the Association and that the Agreement ceases upon termination of funding by the Ministry. ...

Ltd. 80 DTC 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. ...