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7 March 1991 Income Tax Severed Letter- Accumulated vacation leave — whether considered retiring allowance Unedited CRA Tags 248(1) Dear Sir: 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. ...

22 May 1990 Income Tax Severed Letter RRRR256- Whether a U.S. partnership is considered to be a “resident of a contracting State” as defined under paragraph 1 of Article IV of the Canada-U.S. ... Middleton (613) 957-2129 MAY 22 1990 Dear Sirs: This is in reply to your letter of November 20, 1989 wherein you asked whether a U.S. partnership is considered to be a "resident of a contracting State" as defined under paragraph 1 of Article IV of the Canada-U.S. ... As an example, where a Canadian company borrows money from a U.S. partnership whose partners are individuals residing in the U.S. and Germany, the interest paid on the borrowed money will, for tax convention purposes, be considered to be received by the individual partners. ...

7 February 1991 Income Tax Severed Letter- Whether Advance Payments on Crops Could be Considered Loans Unedited CRA Tags Advance Payments for Crops Act Subject: XXX This is in reply to your memorandum of November 27, 1990 addressed to Audit Applications Division requesting comments on whether advances from the above XXX could be considered to be loans by virtue of the operation of. XXX It is set out on page 7 of the Farming Income Tax Guide for 1989 that, “under the Advance Payments for Crops Act... producers of various crops are eligible to receive advance payments on crops stored in their own names from their respective producers' associations” and these advances are considered loans. ...

30 October 1989 Income Tax Severed Letter AC58818- Money in Canadian Currency not Considered Capital Property 5-8818 19(1) S. Leung 613-957-2116 October 30, 1989 Dear Sirs: Re: Paragraph 54(b) of the Income Tax Act (the "Act") We are writing in response to your letter of September 28, 2989 wherein you requested our view on whether, for purposes of subsection 80(1) of the Act, "cash" would be considered capital property within the meaning assigned by paragraph 54(b) of the Act. ... It is therefore, our opinion that, for purposes of subsection 80(1) of the Act, money in Canadian currency would not normally be considered capital property within the meaning assigned by paragraph 54(b) of the Act. ...

10 July 1989 Income Tax Severed Letter AC58094- Activities Considered as Carrying on of a Business R.B. Day (613) 957-2136 19(1) July 10, 1989 19(1) We are writing in reply to your letter of May 1, 1989, wherein you requested our views as to whether the activities described in your letter would be considered to be carrying on a business, the income from which would be subject to income tax. 24(1) OUR COMMENTS For income tax purposes, business is defined, in part, as including a profession, calling, trade, manufacture or undertaking of any kind whatever but does not include an office or employment. ... From the limited information contained in your letter, it would appear that your activities may be considered an undertaking carried on with a view to profit or a reasonable expectation of profit. ...

7 April 1991 Income Tax Severed Letter- Foreign Pension Plan Considered an Employee Benefit Plan and not a Retirement Compensation Plan Unedited CRA Tags 6(1)(a), 56(2), 181(1), 207.6(5), 248(1) Dear Sirs: Re: Request for Technical Interpretation We are writing in reply to your letter of February 14, 1991, in which you request an interpretation of several Income Tax Act (the "Act") provisions as they apply to a specific hypothetical situation. ... A foreign pension plan to which an employer makes contributions for services rendered by an employee is considered an employee benefit plan and not a retirement compensation plan where: 1) the employee was a member of the foreign plan before becoming a Canadian resident, and 2) the services were rendered during the first 60 months following the establishment of Canadian residence by the employee. ... In our view, such an amount would be considered income from employment and included by virtue of subsection 56(2) of the Act. ...

7 September 1990 Income Tax Severed Letter- Whether a band council could be considered a Canadian municipality for purposes of issuing income tax receipts for charitable gifts Unedited CRA Tags 118.1(1)(d) XXX In a letter dated July 24, 1990, Ms. Anita Boscariol of Indian and Northern Affairs Canada requested that we provide you information as to whether your band council could be considered a Canadian municipality for purposes of issuing income tax receipts for charitable gifts. ...

7 March 1991 Income Tax Severed Letter- Whether the subsection 85(8) penalty is applicable to each property included in an election on the basis that where there are several properties listed on one election form each property is considered to be the subject of a separate election Unedited CRA Tags 85(8) Subject: Penalty Application Subsection 85(8) We have been asked to provide a tax practitioner with a technical interpretation of the provisions of subsection 85(8) of the Income Tax Act (the "Act"). Specifically, the practitioner wishes to know if the penalty is applicable to each property included in an election on the basis that where there are several properties listed on one election form each property is considered to be the subject of a separate election. ...

7 May 1990 Income Tax Severed Letter RRRR398- Whether a formula can be considered a “specified amount” for purposes of subsection 191(4) of the Income Tax Act Unedited CRA Tags 191(4), 191(5) Question Subsection 191(4) requires that, for purposes of the taxes levied on certain preferred shares under Parts IV.1 and VI.1 of the Act, an amount be specified in respect of preferred shares issued in the course of a reorganization. ... In Revenue Canada's view can a formula be considered a "specified amount" for purposes of subsection 191(4) of the Act? ...

7 November 1991 Income Tax Severed Letter- Whether a mine located midway between two other mines (located 20 km apart) is considered a new mine Unedited CRA Tags 66.1(6)(a)(iii.1) QUESTION 5. ... Will this mine be considered a new mine for purposes of subparagraph 66.1(6)(a)(iii.1) of the Act? ...