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7 June 1991 Income Tax Severed Letter- Islands that are considered to be a part of the country of Saint Vincent Unedited CRA Tags Reg. 5907(11) Dear Sirs: Re: Saint Vincent This is in reply to your letter dated April 23, 1991. ...

8 March 1990 External T.I. 74595 F- Patent Costs & Legal Fees Considered Capital or Income Expenditures Unedited CRA Tags 18(1)(b) VANCOUVER DISTRICT OFFICE HEAD OFFICE   Specialty Rulings Directorate J. ... With respect to the four questions posed at the close of your submission, our responses are as follows: a)     Because of the capital nature of the expenses, no amounts are deductible in computing the taxpayers income from any source. b)     The patent costs plus the legal costs incurred are capital expenditures that would be included in class 14 in schedule II once the patents themselves have been reacquired by the taxpayer. c)     In view of the above comments, it is our view that these costs cannot be considered "capital nothings". d)     Because these patents do no relate to the taxpayer's consulting business, no costs may be deducted from, nor CCA claimed with respect to, that business. ...

13 September 1990 External T.I. 9021675 F- Demolition of Building Considered Disposition of Property Unedited CRA Tags 13(21) disposition of property, ITR 1102(1)(c) 24(1) 5-902167   L. ... In these latter circumstances, the demolition of the building is considered a disposition and may result in a capital loss in the purchaser's hands. ...

8 March 1990 Income Tax Severed Letter AC74595- Patent Costs & Legal Fees Considered Capital or Income Expenditures Unedited CRA Tags 18(1)(b), Reg. ... With respect to the four questions posed at the close of your submission, our responses are as follows: a) Because of the capital nature of the expenses, no amounts are deductible in computing the taxpayers income from any source. b) The patent costs plus the legal costs incurred are capital expenditures that would be included in class 14 in schedule II once the patents themselves have been reacquired by the taxpayer. c)In view of the above comments, it is our view that these costs cannot be considered "capital nothings". d) Because these patents do no relate to the taxpayer's consulting business, no costs may be deducted from, nor CCA claimed with respect to, that business. ...

7 July 1990 Income Tax Severed Letter- Whether certain assets can be considered to have been “used in an active business” for the purposes of the definition of “qualified small business corporation share” in subsection 110.6(1) and the definition of “small business corporation” in subsection 248(1) Unedited CRA Tags 110.6(1), 248(1) Dear Sirs: This is in reply to your letter of November 15, 1989 in which you requested our opinion on whether certain assets can be considered to have been "used in an active business" for the purposes of the definition of "qualified small business corporation share" (qsbcs) in subsection 110.6(1) and the definition of "small business corporation" (sbc) in subsection 248(1). ...

7 December 1990 Income Tax Severed Letter- Factors to be Considered in Establishing Whehter Particular Shares were Acquired in the Ordinary Course of Business Unedited CRA Tags 138(6), (9) Subject: XXX This is in reply to your memorandum dated September 26, 1990 concerning a referral to you from the Winnipeg District Office and the above noted taxpayer. ... (b) 1984 Conference Report: Q.62 “Factors which have been considered in establishing whether particular shares were or were not acquired in the ordinary course of business are as follows: 1) the nature of the holder's activities, 2) the number and frequency of such share acquisitions by the holder, 3) whether the funds involved represent the initial capitalization of a new subsidiary or the provision of additional operating capital to a subsidiary both of which would indicate permanent capitalization, 4)... 5)...” ...

13 September 1990 Income Tax Severed Letter ACC9658- Demolition of Building Considered Disposition of Property L. ... In these latter circumstances, the demolition of the building is considered a disposition and may result in a capital loss in the purchaser's hands. ...

15 December 1989 External T.I. 59130 F- Accrued Interest on a "Compound Interest" CSB Considered as a "Right or Thing" Unedited CRA Tags 70(2), 70(3) 19(1) 5-9130   Maureen Shea-DesRosierss   (613) 957-8953 December 15, 1989 Dear Sir: Re:  Subsection 70(2) of the Income Tax Act (the "Act") This is in reply to your letter of November 22, 1989 wherein you ask if accrued interest on a "compound interest" Canada Savings Bond ("CSB") represents a "right or thing" for purposes of subsection 70(2) of the Act. ...

22 December 1989 Administrative Letter 59176 F- Annuities Considered Qualified RRIF Investments Unedited CRA Tags 146.3(1) qualified investment, 204 qualified investment, ITR 4900 19(1) 5-9176   D. ...

7 November 1990 Internal T.I. 90M11367 F- Partnership Considered Separate Person Unedited CRA Tags 54.2, 96(1) CTF- 1990 Conference Report ADDITIONAL QUESTION PARTNERSHIP- "PERSON" The Department has expressed the view in the past that section 54.2 does not apply to a partnership which has disposed of all of the assets used in an active business. ...