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23 October 1991 Administrative Letter 912346 F- Penalty Provisions in Connection with Collection Procedures Unedited CRA Tags 239(1(d),162(7)(b), 159(2),159(3) Application of 239(1(d) & 162(7)(b) to 159(2) & (3) Further to our telephone conversation of October 18, 1991, withEr. ... Prosia, he indicated that to the best of his knowledge, the above noted penalty provisions are not given consideration in connection with the collection procedures instituted as a result of the application of 159(3). ...

7 November 1990 Income Tax Severed Letter- Deductibility of Costs Incurred in Connection with a Takeover Bid Unedited CRA Tags none Subject: Deductibility of costs incurred in connection with a takeover bid On November 2, 1990, Mr. ...

11 May 1992 Income Tax Severed Letter 9210710- Letter of Credit in Connection with a RCA CALU ANNUAL MEETING May 11, 1992Question 9 RETIREMENT COMPENSATION ARRANGEMENTSDRAFT/EBAUCHE Supplementary retirement income benefits may be secured for employees with a bank letter of credit. ...

2 May 1991 Internal T.I. 9030807 F- Payments in Connection with the Financing of a Company's Operation Unedited CRA Tags 18(1)(a), 12(1)(a), 20(1)(e), 20(1)(f)(ii)   May 2, 1991   Belleville District Office               Rulings Directorate J.E. ... M.N.R., [1949] S.C.R. 287 [49 DTC 514], where it was held that commission payments were not allowable as deductible expenses since they were incurred in connection with the financing of the business and were not related to the income earning process. ... Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business.  ...

2 May 1991 Income Tax Severed Letter 7-903080- Payments in Connection with the Financing of a Company's Operation May 2, 1991 Belleville District Office Rulings Directorate J.E. ... M.N.R., [1949] S.C.R. 287 [49 DTC 514], where it was held that commission payments were not allowable as deductible expenses since they were incurred in connection with the financing of the business and were not related to the income earning process. ... Broadhurst's summary in the 1989 Conference Report ("Income Tax Treatment of Foreign Exchange Forward Contracts, Swaps and Other Hedging Transactions" p. 26:13): 000321 The case law in Canada has consistently regarded payments made in connection with the financing of a company's operation as being on capital account unless the taxpayer is engaged in a money-lending business. ...

25 November 2005 External T.I. 2005-0122351E5- Service Connection and CRCE Unedited CRA Tags Reg 1219(1) 66(12.6) Principal Issues: Whether the cost to design and purchase certain property will qualify as CRCE under paragraph 1219(1)(a) of the Regulations as having been incurred for the purpose of making a service connection to a qualifying project for the transmission of electricity to a purchaser. ... A determination by Transmission that particular costs are required to be incurred by a Generator in order to permit interconnection with the provincial transmission system is a factor to be considered in determining whether such costs were incurred for the purpose of making a service connection to the project for the transmission of electricity to a purchaser thereof as required by paragraph 1219(1)(a) of the Regulations. ... As such, notwithstanding that a cost incurred by a PBC for the purpose of making a service connection to a qualifying project may qualify for inclusion in CRCE under paragraph 1219(1)(a) of the Regulations, the PBC may be precluded from making a renunciation to a FTS investor in respect of such cost. ...

28 December 1989 Income Tax Severed Letter 5-8491- Tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund-raising activities Unedited CRA Tags 12.2(3), 56(1)(d.1), Reg. 304(1)(c) Dear Sirs: This is in reply to your letter of August 10, 1989, requesting our views on the tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund raising activities. ...

7 August 1990 Income Tax Severed Letter- Technical interpretation in connection with a hypothetical situation in which arm's length partners agree to allocate partnership income and loss Unedited CRA Tags 96(1)(d), 96(1)(g), 103 Dear Sirs: Re: Request for Technical Interpretation Paragraphs 96(1)(d) and (g) and Section 103 of the Income Tax Act (the "Act") We are writing to reply to your letter dated March 19, 1990 wherein you requested a technical interpretation in connection with a hypothetical situation in which arm's length partners agree to allocate partnership income and loss. ...