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6 March 1991 External T.I. 9033605 F- Accumulated Vacation Leave- Whether Considered Retiring Allowance Unedited CRA Tags 6(3), 248(1) retiring allowance 5-903360 Dear Sirs: Re:  Accumulated Vacation Leave Whether considered Retiring Allowance This is in reply to your letter of November 20, 1990 concerning the above-mentioned subject. ... When an employee terminates employment and a payment is made in respect of accumulated vacation leave not taken prior to retirement, the payment  of said credits is considered to be ordinary remuneration and is included in the employee's income in the year of receipt pursuant to subsection 6(3) of the Income Tax Act as stated in paragraph 5 of Interpretation Bulletin IT-337R2.  ...

5 March 1996 Income Tax Severed Letter 9528801- WHETHER COMPRESSED GAS CONSIDERED FUEL. ... Reasons: To be considered "Fuel" the gas must be combusted. ... The court held that to be considered "fuel" the gas must be combusted. ...

27 March 1990 Ministerial Correspondence 59134 F- Revenue Guarantees Considered Prescribed Benefits for Tax Shelter Purposes Unedited CRA Tags 237.1(1), 231(6) 19(1) File No. 5-9134   C.R. Bowen   (613) 957-2096 March 27, 1990 Dear Sirs: Re:  Revenue Guarantees as Prescribed Benefits  for Tax Shelter Reporting Purposes We are writing in reply to your letter of November 22, 1989, wherein you requested our comments on the amount of a revenue guarantee that would be considered a prescribed benefit for the purposes of the definition of "tax shelter" in subsection 237.1(1) of the Income Tax Act (the "Act"). ... Where a revenue guarantee provided to a limited partnership may reasonably be considered to ensure that a limited partner will receive a return of all or a portion of his outlay in respect of a tax shelter, the amount of such benefit will be considered a prescribed benefit for the purposes of subsection 231(6) of the Regulations.  ...

13 March 1990 Income Tax Severed Letter AC59482- Capital Gains Deduction- Inventory of Real Estate Corporation Considered Used in Active Business Unedited CRA Tags 110.6(1), 248(1) 19(1) 5-9482 D. ... Her Majesty the Queen [[1984] C.T.C. 122] (84 DTC 6119), it was suggested that inventory was not considered used in the business until it was sold. ... You have requested our opinion on whether an asset held as an adventure or concern in the nature of trade, is considered used in an active business. ...

27 March 1990 Income Tax Severed Letter AC59134- Revenue Guarantees Considered Prescribed Benefits for Tax Shelter Purposes Unedited CRA Tags 237.1(1), Reg. 231(6) 19(1) 5-9134 C.R. Bowen (613) 957-2096 March 27, 1990 Dear Sirs: Re: Revenue Guarantees as Prescribed Benefits for Tax Shelter Reporting Purposes We are writing in reply to your letter of November 22, 1989, wherein you requested our comments on the amount of a revenue guarantee that would be considered a prescribed benefit for the purposes of the definition of "tax shelter" in subsection 237.1(1) of the Income Tax Act (the "Act"). ... Where a revenue guarantee provided to a limited partnership may reasonably be considered to ensure that a limited partner will receive a return of all or a portion of his outlay in respect of a tax shelter, the amount of such benefit will be considered a prescribed benefit for the purposes of subsection 231(6) of the Regulations. ...

6 July 1989 Income Tax Severed Letter AC58087- Tax Deduction for Employment Outside Canada- Architectural Service Considered Qualified Activity 5-8087 S. ... You also feel that it is not necessary for an employer to have a permanent establishment in a foreign country to be considered to be carrying on a business in that country. ... Generally, we agree that it is not necessary for an employer to have a permanent establishment in a foreign country before he can be considered to be carrying on a business in that country. ...

11 August 1997 External T.I. 9626335- WHETHER MULTIPLE PROPERTIES CONSIDERED "A PROPERTY? ... Principal Issues: Whether multiple properties considered "a property"? ... ISSUE # 1: 1.Would the adjacent lots be considered a single property for purposes of subsections 248(20) and 248(21) of the Act or would each lot be considered a separate property? ...

11 September 1989 Income Tax Severed Letter 5-8470- Whether a corporation would be considered for puposes of paragraph 125(7)(e) to employ in the business of leasing real property more than five full time employees throughout the year Unedited CRA Tags 125(7)(e) Dear Sirs: This is in reply to your letter of August 2, 1989, wherein you requested our views as to whether in the two situations you described the corporation would be considered for purposes of paragraph 125(7)(e) of the Income Tax Act (the "Act") to employ in the business of leasing real property more than five full time employees throughout the year. ... Consequently, X Co. and Y Co. will not be considered for purposes of subparagraph 125(7)(e)(i) of the Act, to employ. more than five full-time employees in their leasing business and would not be considered to be carrying on an active business. ...

7 November 1991 Income Tax Severed Letter- Whether equipment considered to be “available for use” for purposes of draft subsection 13(27) in two situations Unedited CRA Tags 13(27) 1991 BC TAX EXECUTIVES MEETING QUESTION 11. Is equipment considered to be "available for use" for purposes of draft subsection 13(27) of the Income Tax Act (the "Act") in the following two situations? ... In the first situation, the equipment could be considered to become "available for use" in the particular taxation year by virtue of draft paragraph 13(27)(a) of the Act since the equipment was in fact used for the first time in that year in accordance with its intended purpose. ...

15 May 1990 Income Tax Severed Letter RRRR345- Whether the amount of the deduction for a contribution of qualified investments to a deferred income plan be considered as a prescribed benefit for the purposes of regulation 231(6) Unedited CRA Tags Reg. 231(6), 237.1 May 15, 1990 Vancouver District Office Conference Questions May 1990 a) Assume that the shares issued by a corporation to the public are eligible as qualifying investments for certain registered deferred income plans, i.e. ... If these shares are contributed by an investor to his or her RRSP, RRIF OR DPSP etc., will the amount of the deduction be considered as a prescribed benefit for the purposes of regulation 231(6) of the Income Tax Regulations? b) If a limited partner of a limited partnership is entitled to exchange his partnership unit for partnership property that has a fair market value equal to the fair market value of the partnership unit at the time of disposition, will the fair market value of the partnership property so distributed be considered a prescribed benefit for the purposes of regulation 231(6) of the Income Tax Regulations? ...