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5 March 1996 Income Tax Severed Letter 9528801- WHETHER COMPRESSED GAS CONSIDERED FUEL. ... Reasons: To be considered "Fuel" the gas must be combusted. ... The court held that to be considered "fuel" the gas must be combusted. ...

13 March 1990 Income Tax Severed Letter AC59482- Capital Gains Deduction- Inventory of Real Estate Corporation Considered Used in Active Business Unedited CRA Tags 110.6(1), 248(1) 19(1) 5-9482 D. ... Her Majesty the Queen [[1984] C.T.C. 122] (84 DTC 6119), it was suggested that inventory was not considered used in the business until it was sold. ... You have requested our opinion on whether an asset held as an adventure or concern in the nature of trade, is considered used in an active business. ...

27 March 1990 Income Tax Severed Letter AC59134- Revenue Guarantees Considered Prescribed Benefits for Tax Shelter Purposes Unedited CRA Tags 237.1(1), Reg. 231(6) 19(1) 5-9134 C.R. Bowen (613) 957-2096 March 27, 1990 Dear Sirs: Re: Revenue Guarantees as Prescribed Benefits for Tax Shelter Reporting Purposes We are writing in reply to your letter of November 22, 1989, wherein you requested our comments on the amount of a revenue guarantee that would be considered a prescribed benefit for the purposes of the definition of "tax shelter" in subsection 237.1(1) of the Income Tax Act (the "Act"). ... Where a revenue guarantee provided to a limited partnership may reasonably be considered to ensure that a limited partner will receive a return of all or a portion of his outlay in respect of a tax shelter, the amount of such benefit will be considered a prescribed benefit for the purposes of subsection 231(6) of the Regulations. ...

6 July 1989 Income Tax Severed Letter AC58087- Tax Deduction for Employment Outside Canada- Architectural Service Considered Qualified Activity 5-8087 S. ... You also feel that it is not necessary for an employer to have a permanent establishment in a foreign country to be considered to be carrying on a business in that country. ... Generally, we agree that it is not necessary for an employer to have a permanent establishment in a foreign country before he can be considered to be carrying on a business in that country. ...

11 September 1989 Income Tax Severed Letter 5-8470- Whether a corporation would be considered for puposes of paragraph 125(7)(e) to employ in the business of leasing real property more than five full time employees throughout the year Unedited CRA Tags 125(7)(e) Dear Sirs: This is in reply to your letter of August 2, 1989, wherein you requested our views as to whether in the two situations you described the corporation would be considered for purposes of paragraph 125(7)(e) of the Income Tax Act (the "Act") to employ in the business of leasing real property more than five full time employees throughout the year. ... Consequently, X Co. and Y Co. will not be considered for purposes of subparagraph 125(7)(e)(i) of the Act, to employ. more than five full-time employees in their leasing business and would not be considered to be carrying on an active business. ...

7 November 1991 Income Tax Severed Letter- Whether equipment considered to be “available for use” for purposes of draft subsection 13(27) in two situations Unedited CRA Tags 13(27) 1991 BC TAX EXECUTIVES MEETING QUESTION 11. Is equipment considered to be "available for use" for purposes of draft subsection 13(27) of the Income Tax Act (the "Act") in the following two situations? ... In the first situation, the equipment could be considered to become "available for use" in the particular taxation year by virtue of draft paragraph 13(27)(a) of the Act since the equipment was in fact used for the first time in that year in accordance with its intended purpose. ...

15 May 1990 Income Tax Severed Letter RRRR345- Whether the amount of the deduction for a contribution of qualified investments to a deferred income plan be considered as a prescribed benefit for the purposes of regulation 231(6) Unedited CRA Tags Reg. 231(6), 237.1 May 15, 1990 Vancouver District Office Conference Questions May 1990 a) Assume that the shares issued by a corporation to the public are eligible as qualifying investments for certain registered deferred income plans, i.e. ... If these shares are contributed by an investor to his or her RRSP, RRIF OR DPSP etc., will the amount of the deduction be considered as a prescribed benefit for the purposes of regulation 231(6) of the Income Tax Regulations? b) If a limited partner of a limited partnership is entitled to exchange his partnership unit for partnership property that has a fair market value equal to the fair market value of the partnership unit at the time of disposition, will the fair market value of the partnership property so distributed be considered a prescribed benefit for the purposes of regulation 231(6) of the Income Tax Regulations? ...

7 July 1991 Income Tax Severed Letter- Criteria to be considered in the application of section 80 of the Income Tax Act where debt is restructured because of a debtor's financial difficulty Unedited CRA Tags 80 Issue: Criteria to be considered in the application of section 80 of the Income Tax Act (the "Act") where debt is restructured because of a debtor's financial difficulty. ... The application of section 80 to restructuring that do not meet the above criteria would have to be considered on a case by case basis. ... The possible application of section 80 to a debt restructuring arising because of a debtor's financial difficulty was considered in a 1984 advance income tax ruling request of XXX We ruled that section 80 would not be applied to XXX by virtue only of the coming into effect of restructuring plan and the modification of the terms of the indebtedness. ...

7 December 1991 Income Tax Severed Letter- Whether venture capital corporations are considered to be small business investments for purposes of subsection 207.1(5) Unedited CRA Tags 207.1(5), Reg. 4900, 5100, 6700 Dear XXX Re: Venture Capital Corporations We are writing in reply to your letter of July 15, 1991, in which you ask whether venture capital corporations are considered to be small business investments for purposes of subsection 207.1(5) of the Income Tax Act (the "Act"). ... For this purpose, an annuitant of an RRSP and the RRSP itself are considered to be related persons. ... Due to the detail and complexity of the Regulations regarding these issues, the foregoing comments are meant only to provide an overview of the relevant provisions and under no circumstances are they to be considered to be either comprehensive or all inclusive. ...

7 July 1990 Income Tax Severed Letter- Whether donations to a particular entity are considered gifts to Her Majesty Unedited CRA Tags 110.1(2), 118.1(2), Reg. 3500, 3501 Dear Sirs: This is in reply to your letter of January 16, 1990 wherein you requested our views as to whether donations to the XXX could be considered gifts to Her Majesty. It is our view that donations to the XXX could be considered gifts to Her Majesty for purposes of sections 110.1 and 118.1 of the Income Tax Act (the "Act"). ...