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24 February 2000 Internal T.I. 1999-001425-- summary under Subsection 212(13.2) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(13.2) Interest capitalized as inventory pursuant to s. 18(3.1) would be considered to be deductible for purposes of s. 212(13.2). ...

23 July 1992 Memorandum 922191 (April 1993 Access Letter, p. 128, ¶C5-188)-- summary under Regulation 101 Summary Under Tax Topics- Income Tax Regulations- Regulation 101 Where both an employer and Agriculture Canada were paying a portion of a rent differential allowance to an employee, each would be considered an employer for purposes of the requirement to withhold tax and to report the benefit on a T4 supplementary slip. ...

23 July 1992 Memorandum 922191 (April 1993 Access Letter, p. 128, ¶C5-188)-- summary under Subsection 200(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(2) Where both an employer and Agriculture Canada were paying a portion of a rent differential allowance to an employee, each would be considered an employer for purposes of the requirement to withhold tax and to report the benefit on a T4 supplementary slip. ...

8 March 2007 Internal T.I. 2006-0214291I7- Part XIII withholding tax-- summary under Paragraph 212(1)(b) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(b) "Where a loan agreement provides for a gross-up of the interest payments, our position is that paragraph 18(1)(t) of the Act does not apply to the gross-up amount and that the gross-up amount may be considered as additional interest for the purposes of paragraph 212(1)(b).... ...

16 September 2011 Internal T.I. 2010-0383571I7- Transfer of Property to a US Head Office-- summary under Subsection 76.1(1) Summary Under Tax Topics- Income Tax Act- Section 76.1- Subsection 76.1(1) s. 76.1 would not apply to a "loan" between the US head office of a US corporation and its Canadian branch that is now being closed down, as such loan would not be considered to exist. ...

17 July 1997 Internal T.I. 9700547- DEDUCTION OF TERMINAL LOSS FROM RESOURCE PROFITS-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) The disposal of machinery would be considered as related and attributable to a mining business for purposes of ss.9 and 18(1)(a) even though such business was inactive and there were no mining operations. ...

17 July 1997 Internal T.I. 9700547- DEDUCTION OF TERMINAL LOSS FROM RESOURCE PROFITS-- summary under Resource Activity Summary Under Tax Topics- Income Tax Regulations- Regulation 1206- Subsection 1206(1)- Resource Activity The disposal of machinery held in an inactive mining business would be considered as "activities that the taxpayer undertakes as a consequence of" the mine production/processing operation. ...

31 May 1995 Internal T.I. 9508876- RELATED EMPLOYERS FOR RETIRING ALLOWANCE-- summary under Paragraph 60(j.1) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(j.1) "If any part of the service with a previous employer is recognized under the current employer's pension plan, all the years of service with the former employer will be considered service with a 'person related to the employer'. ...

27 July 1995 Internal T.I. 9514966- CAPITAL TAX- RESOURCE PROFITS-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Provincial capital tax is considered to be paid for the purpose of gaining a producing income from the business providing [sic] there is no requirement that there be income in order for the capital tax to be levied. ...

., capital tax attributed to facilities and equipment used in production is considered as a deduction in computing resource profits. ...