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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.  ...

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? ...

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. ...

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. ...

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. ...

., whether an individual is unemployable, we are of the view that AISH payments would not be considered similar to a family allowance payment under the former Family Allowance Act. ... You have never applied for individual funding for someone who has any reserve money from any source, so you do not know if that is considered in the granting of funding. ... Our Views Based on the test used to determine eligibility for AISH, i.e., whether an individual is unemployable, we are of the view that AISH payments would not be considered similar to a family allowance payment under the former Family Allowance Act. ...

Principal Issues: Whether the particular partners of a UK LP (a) have indirect control over the voting power of Holdco held by the UK LP; (b) considered to indirectly own more that 10% of the shares and capital of Holdco; and (c) considered to be dealing at arm's length with Canco, a subsidiary of Holdco. ... Issue 2- Whether LP1 and LP3 are considered to own indirectly shares of Holdco for purposes of paragraph 3 of Article 10? ... By analogy, you reason that a partner who is considered to be dealing at arm’s length with a partnership should also be considered to be dealing at arm’s length with the corporation controlled by the partnership. ...

Graham September 8, 2017 Dear XXXXXXXXXX: Re: Foreign non-business income tax considered paid by member of a partnership This technical interpretation is in reply to your email of November 27, 2014, regarding the calculation of a foreign tax credit by a member of a partnership. ... B’s non-business income tax in respect of Country X would be considered to include his share thereof paid by AB Partnership. ... B seeks to have something other than a pro-rata amount of the total foreign withholding tax paid by the partnership considered to be a non-business income tax paid by them, the following additional information should, in our view, be provided to support their claim: the name of each partner of the partnership; the Canadian tax identification number, if any, of each partner; the country of residence of each partner; the nature and amount of each partner’s interest in the partnership; the calculation and amount of income allocated to each partner; and the calculation and amount of foreign withholding tax considered to be paid by each partner. ...

Shea-DesRosiers Attention: XXXXXXXXXX December 4, 1995 Dear Sir/Madam, Re: Whether cash gifts and presents to be considered "business income" This is in reply to your letter of September 26, 1995 concerning the above-mentioned subject. You ask whether cash gifts and presents, received by an ordained minister employed with a church, as a guest speaker at various religious organizations, for providing eulogies at funerals and officiating at marriages and other religious ceremonies without any fee having been requested, can be considered business income. ... You state in the first paragraph of your letter that the ordained minister is "employed with a church" and in the last paragraph of your letter you enquire as to whether the gifts and presents should be considered "business income". ...