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Brake Attention: XXXXXXXXXX November 13, 1997 Dear Sirs: Re: Issuance of T2202A for Upgrading and Music Programs This is in reply to your letter of April 28, 1997, regarding a student's eligibility for the tuition tax credit in connection with tuition fees paid for courses that are not at a post-secondary level, such as high school credits and academic upgrading courses for adult students, as well as all of your music programs. ...

The taxpayer completed construction of the facility on January 1, 1997, at which time all of the assets acquired in connection with the construction of the facility became available for use for purposes of capital cost allowance. ...

The Department will now consider that "facility" as used in that subparagraph should be interpreted in connection with the words "golf course" as to only include recreational amenities provided by a golf club. ...

The Department will now consider that "facility" as used in that subparagraph should be interpreted in connection with the words "golf course" as to only include recreational amenities provided by a golf club. ...

In addition, as indicated in paragraph 6 of Interpretation Bulletin IT-99R4, it is the Department’s practice to allow a taxpayer to deduct amounts expended in connection with legal and accounting fees incurred for advice and assistance in making representations after having been informed that the taxpayer’s income or tax is to be revised, whether or not a formal notice of objection or appeal is subsequently filed. ...

Our Comments In our view, an offence under subsection 239(2.3) of the Act occurs when any person (including an officer, employee or agent of such a person) provided with an individual's SIN pursuant to the Act, knowingly and without the individual's written consent uses, communicates or allows to be communicated the SIN, if such use or communication is for some purpose other than: 1. a purpose for which the SIN was provided by the individual; 2. as required or authorized by law; or 3. in the course of duties in connection with the administration or enforcement of the Act. ...

Generally, an RCA is a plan or arrangement under which contributions are made by an employer or former employer of the taxpayer to another person in connection with benefits that are to be or may be paid to a person as a result of a substantial change in the services rendered by the taxpayer, the retirement of the taxpayer or the loss of an office or employment of the taxpayer. ...

G Ltd. was incorporated in connection with the acquisition of the Land although it is expected that G Ltd. will purchase many other real estate properties. ...

Our Comments We note that a taxpayer using the cash method to compute income from a farming business may elect to roll over inventory owned in connection with the farming business to a corporation under subsection 85(1) of the Act. ...

In connection with computer, the student must pay a technology fee of $XXXXXXXXXX each semester. ...