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We are therefore unable to provide specific confirmation as to the deductibility of the bonuses mentioned in your example but would suggest take these factors into consideration in deciding on the amount of bonuses to be charged to 24(1) operations. ...

In addition to the facts set out in the above-noted memoranda careful consideration has been given to the information provided to us by 19(1) and 19(1) 24(1) at the February 27, 1990 meeting in our office which was attended by you. ...

Apart from this consideration, we are reasonably confident at this time that, should a ruling request be received in the near future in which the assignment of the settlement agreement to an appropriate assignee was an integral part and it otherwise complied with the provisions of paragraph 5 of Interpretation Bulletin IT-365R2, it would receive a favourable response. ...

14 November 1991 Ministerial Correspondence 912654 F- Attribution Rules Unedited CRA Tags 74.1(1), 74.3(1) Dear Sirs: Re:  Attribution Rules This is in reply to your letter of August 26, 1991 addressed to the Vancouver District Office which was forwarded to this office for consideration and reply.  ...

Such an agreement requires the purchaser of the shares to pay an amount to the vendor in consideration of the vendor agreeing to be subject to the terms with respect to non-competition.  ...

Our Interpretation Bulletin IT-419 is enclosed for your consideration in this regard. ...

The Draft Amendments to the Income Tax Act and Related Statutes (July, 1990) propose the following amendments to the definition of "investment expense" dealing with the issue you have raised as follows:      "(2) Paragraph (a) and (b) of the definition "investment expense" in subsection 110.6(1) of the said Act are repealed and the following substituted therefor:      "(a) the aggregate of all amounts each of which is an amount deducted in computing the individual's income for the year from property (except to the extent that the amount was otherwise taken into account in computing the individual's investment expense or investment income for the year) other than any such amount deducted under      (i)  paragraph 20(1)(c), (d), (e), (e.1), or (k) in respect of borrowed money that was used by the individual to or that was used to acquire property that was used by the individual      (A)  to make a payment as consideration for an income-averaging annuity contract,      (B)  to pay a premium under a registered retirement savings plan, or      (C)  to make a contribution to a registered pension fund or plan or a deferred profit sharing plan", The Explanatory Notes to the Draft Income Tax Amendments go on to explain that:      "Paragraph (a) of this definition has also been amended to exclude from an individual's investment expense interest and other expenses deducted under paragraphs 20(1)(c), (d), (e), (e.1), or (k) in respect of indebtedness incurred for a purpose set out in subsection 18(11), irrespective of when the indebtedness was incurred". ...

The MLP is established on the basis of a new car and takes into consideration the cost of the optional features added to the car assuming they are owned by the leasing agency.  ...

Our Comments Generally, the reasonableness of a reserve will be acceptable if in the calculation of the reserve, consideration is given to any mortgages assumed by a buyer in situations where the vendor has previously given a mortgage to a third party either at the time of acquisition of the land or to finance the cost of improvements to the land including construction of a building on the land.  ...

You have submitted for our consideration the following hypothetical  situation: Hypothetical Situation:-      Limited Partnership A ("Partnership") is a Limited Partnership  which carries on the business (in Canada) of mining, processing and sales of the processed product.-      Partnership is owned as to 60% by a German resident individual, Mr. ...