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.- Q.50-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) Since a partnership interest is not considered to be an interest in the underlying assets, an interest in a partnership with real estate inventory is eligible property. ...

Annual Conference, Q. 16 (January- February 1993 Access Letter, p. 56)-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) Because a licence of property or rights by a parent to its subsidiary is not extinguished until after the holder and the issuer of the license become the same person, there is considered to be a distribution of property to the parent on the winding-up. ...

.- Q62-- summary under Subsection 231.1(1) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1) It is RC's general practice to request accountants to produce specific working papers for examination where they can reasonably be considered an extension of the client's records. ...

., the attorney is considered to have a right referred to in s.251(5)(b)(i) and s.256(1.4)(a) where the powers under the CPA can be exercised at any time. ...

93 C.M.TC- Q. 5-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax The branch-level interest tax imposed pursuant to I.R.C. s. 884(f)(1)(B) is not considered to be an "income or profits tax" for purposes of s. 126(7)(a) or (c) because it is not imposed on the branch's income or profits. ...

11 May 1990 Memorandum (October 1990 Access Letter, ¶1494)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose GST interest is considered in the same light as provincial sales tax interest and is deductible from income. ...

93 C.M.TC- Q. 5-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The branch-level interest tax imposed on a U.S branch of a Canadian company pursuant to I.R.C. s. 884 (f)(1)(B) is considered to be a deductible expense because it is an outlay incurred for the purpose of gaining or producing business income. ...

93 C.M.TC- Q. 4-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 The continuance of a corporation incorporated in Canada to the United States will not result in that corporation ceasing to be considered to have been created in Canada for purposes of Article IV of the U.S. ...

.- Q.64-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition The position in IT-125R3 respecting when a farm-out arrangement is not considered to be a disposition does not extend to the disposition of other property under agreements similar to farm-outs. ...

.- Q.47-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) Where a Canadian corporation borrows funds from an arm's length lender and the Canadian corporation's non-resident parent guarantees the loan for no consideration, the Canadian corporation will not be considered to have received a taxable benefit from the parent. ...