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In your letter you have outlined four hypothetical scenarios for our consideration. ...

1993 External T.I. 9332045 F- Prescribed Shares Unedited CRA Tags ITR 6202.1(2)(b) 5-933204 XXXXXXXXXX Resource Industries Attention:  XXXXXXXXXX December 8, 1993 Dear Sirs: RE:  Flow-through Shares This is in reply to your letter of November 4, 1993 and will confirm our view that the common shares issued to employees by XXXXXXXXXX Our position is being confirmed following consideration of submissions made by yourself and XXXXXXXXXX on your behalf and our discussions with the same parties, the Department of Finance and the Department of Justice. ...

The participant will receive no other consideration for his donation. ...

Whether the amount would qualify as an eligible capital expenditure remains a question of fact.Business Income Where the renting or leasing of property forms part or all of the taxpayer's business, any amount received by him as consideration for granting a lease would be included in his income pursuant to section 9 of the Act. ...

" Instead, the Court recommended the following approach: (a)     analyze the matter in terms of categories of property and types of taxation; (b) identify the various connecting factors (i.e. factors connecting the property to a location on or off a reserve) which are potentially relevant; (c) determine the weight to be given the connecting factors in the light of three considerations: 1.      ...

Following a thorough analysis of this case and due consideration of extensive input from the Indian community, the Department has developed four guidelines dealing with the taxation of employment income of Indians. ...

Nevertheless, we offer the following general comments for your consideration. ...

We, however, offer the following comments for your consideration. Regulation 5000(1) provides that shares of a mutual fund corporation and units of certain investment trusts will not be foreign property for the purposes of Part XI of the Income Tax Act (the "Act") in respect of a particular month provided the trust or corporation has not acquired any foreign property after June 30, 1971 or if at no time during its "relevant period for the particular month" has the cost amount of its foreign property exceeded 20% of the cost amount of all its property. ...

We have brought this matter to the attention of the Department of Finance for their consideration. ...

More submissions were received and these were given serious consideration before the final guidelines were issued in June of 1994. ...