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15 December 1989 Income Tax Severed Letter AC59130- Accrued Interest on a "Compound Interest" CSB Considered as a "Right or Thing" 5-9130 M. ...

1 June 1990 Income Tax Severed Letter ACC9059- Inventory Considered Depreciable Property 24(1) 24(1) New Information 24(1) Issues The Issues are: 24(1) Your Views You agree with our original opinion that 24(1) Even if the properties are considered to be inventory, you the Department's policy as described in paragraph 16 of IT-102R is to recognize them as depreciable property: Where stock in trade is transferred temporarily from the taxpayer's inventory for the purpose of renting the property on a short-term basis...the property may be classed as capital property while it is being rented. ... As outlined in paragraphs 20 and 21 of IT-331R, the lessor must acquire the property to be leased and the property must be leased before the equipment is considered to qualify for the ITC. ...

18 January 1996 Internal T.I. 9530626- MULTI-EMPLOYER WAGE LOSS PLAN NOT CONSIDERED 2 PLANS Unedited CRA Tags 6(1)(f) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: whether 6(1)(f) would apply to all employees covered by a multi-employer plan where one employer out of many makes no contributions to the plan Position: 6(1)(f) would not apply Reasons: while 6(1)(f) only applies where the employee's employer has made a contribution, we have previously expressed the view that a single plan cannot be regarded as more than one plan in order that part of the plan be considered an employee-pay-all plan: however in a multi-employer situation, there may be many near-identical plans administered by a single plan administrator. ...

24 June 1992 External T.I. 9207495 F- Indian Band Considered To Be Municipality Unedited CRA Tags 110.1(1)(a)(iv), 118.1(1) total charitable gifts 920749 24(1) J.D. ...

16 December 1988 Income Tax Severed Letter 7-3381- [IT-96R4, paragraphs 1 and 2 (allocation of issue price between debentures and warrants) IT-114, paragraphs 3 and 24 (deductibility of discount considered to be the equivalent of interest)] December 16, 1988 HEAD OFFICE Financial Industries Division B. Dwyer 957-2744 Subject: IT-96R4, paragraphs 1 and 2 (allocation of issue price between debentures and warrants) IT-114, paragraphs 3 and 24 (deductibility of discount considered to be the equivalent of interest) This memorandum is in response to your memorandum dated October 18, 1988, in which you asked for our comments on the above-noted matters. ...

If a deceased individual was separated at death, is the estranged spouse considered a spouse, or can the dependent children be considered to have received a refund of premiums? ...

In other words, whether in fact the non-resident transferor could be considered a taxpayer for purposes of subparagraph 13(7)(e)(ii) and whether property that is depreciable property for a transferee could be considered capital property of a non-resident transferor. ... However, in light of comments made on the meaning of the term “taxpayer,” you have also asked whether US Corp is considered a taxpayer for purposes of the definition of “capital property” and therefore whether the Trademarks could be considered to be a capital property of US Corp immediately before the transfer. ... However the term “taxpayer” has also been considered by the courts in various situations. ...

Position: It is our opinion that the $XXXXXXXXXX payment, per unit, made by the producer will be considered ECE for purposes of section 14 of the Act. ... Question 1: Will the license be considered prepaid rent or an eligible capital expenditure ("ECE")? ... In our view, as a result of this test, an amount received by a producer in exercising put options would be considered proceeds from the disposition of eligible capital property. ...

ISSUES In order for income from property to be considered income from active business under subparagraph 95(2)(a)(i), the conditions of both clauses 95(2)(a)(i)(A) and (B) must be met. ... Assets will be considered to be at risk in a business where the permanent removal of such assets would have a destabilizing effect on the business. ... Briefly put, Ensite supports the precedent that for property to be considered part of an active business, and for the income from said property to be considered income from the active business, "withdrawal of the property must ‘have a decidedly destabilizing effect on the corporate operations'. ...

Could the benefit conferred by Canco to CFA be considered a contribution of capital for purposes of paragraph 53(1)(c)? Where transfer prices differ from arm’s length terms, it can generally be considered that a benefit is conferred on the person overcharging or underpaying for goods or services. ... On this basis, it is our view that the benefit conferred in the situation described cannot be considered a capital contribution by Canco to CFA for purposes of paragraph 53(1)(c). ...