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As stated in paragraph 12 of Interpretation Bulletin IT 73R6, the term "principal purpose" is not a defined term in the Act for the purposes of the definition of "specified investment business" in subsection 125(7), but it is considered to be the main or chief objective for which the business is carried on. ...

A business would not be considered to have commenced if serious and reasonable efforts are not made to commence normal business operations. ...

., the consideration described in s. 85(1)(b) will be considered to have been reduced to the elected amount of $200). ...

In addition, the definition of "qualified activities" is relevant only in determining what amount of the cost of labour and the cost of capital is considered to be the "cost of manufacturing and processing labour" and the "cost of manufacturing and processing capital". ...

14 May 2003 Internal T.I. 2003-0181477 F- DEDUCTIBILITE DES INTERETS-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) deductible interest is reduced by amortization of premium arising from loan’s deliberate issuance at above-market interest rate Regarding the deductibility of interest where a loan had an above-market rate of interest and a premium was received on its issuance, the Directorate stated: [I]f a premium results from the fact that a debt obligation is intentionally issued at a rate of interest above the market rate in order to obtain a premium, the otherwise deductible interest expense will not be considered reasonable and will be reduced by the amount of the premium amortized over the term of the debt obligation. ...

., the corporate general partner [of LPII] has no substantive economic interest in the partnership,.01%, the corporate general partner's nominal interest need not be considered when determining whether this test is met. ...

…(ii)…applies where it can reasonably be considered that the distribution is derived from an amount received by the trust as a capital dividend on a share of a corporation resident in Canada. ...

30 July 2003 Internal T.I. 2003-0024037- ACB OF LAND & BUILDING-- summary under Paragraph 20(1)(cc) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(cc) ss. 20(1)(cc), (dd) and (ee) deductions for amounts otherwise on capital account Respecting the determination of ACB of where a medical doctor acquired land and constructed a building that is used to earn business income, CRA stated: [G]enerally all of the outlays and expenses incurred in respect of the acquisition of the land and construction of the building will be considered incurred on account of capital, and consequently, will constitute part of the ACB of the particular properties. ...

Thus, the "Payroll Taxes" and "Social Security Taxes" in this situation must be considered "non-business income taxes" …. ...

16 September 2003 Internal T.I. 2003-0023957 F- Droits et biens crédit personne mariée-- summary under Paragraph 118(1)(a) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(a) income of deceased from rights or things (included in separate return) is excluded from income for s. 118(1)(a) purposes In confirming that income from rights or things, included in a separate return of a deceased spouse pursuant to s. 70(2), does not count towards the deceased's income in the taxation year of the deceased’s death for the purpose of determining the amount that could be claimed in the terminal return of the deceased spouse as a married or common-law partner credit under s. 118(1)(a), CCRA stated: [T]he deceased spouse's return of income from January 1 of the year of death to the date of death and the separate return filed pursuant to subsection 70(2) are considered as filed by different taxpayers. ...