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22 December 1989 Income Tax Severed Letter AC59176- Annuities Considered Qualified RRSP Investments December 22, 1989 Dear Sirs: This is in reply to your letter dated December 4, 1989 in which you asked whether a life annuity, a fixed term annuity or a term certain annuity are qualified investments for a trust governed by a registered retirement income fund (RRIF). ...

7 November 1991 Income Tax Severed Letter- Whether a mineral resource that is sold to another taxpayer is still considered a mineral resource Unedited CRA Tags 248(1) QUESTION 7. ...

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 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 Income Tax Severed Letter AC59130- Accrued Interest on a "Compound Interest" CSB Considered as a "Right or Thing" 5-9130 M. ...

1 June 1990 Income Tax Severed Letter ACC9059- Inventory Considered Depreciable Property 24(1) 24(1) New Information 24(1) Issues The Issues are: 24(1) Your Views You agree with our original opinion that 24(1) Even if the properties are considered to be inventory, you the Department's policy as described in paragraph 16 of IT-102R is to recognize them as depreciable property: Where stock in trade is transferred temporarily from the taxpayer's inventory for the purpose of renting the property on a short-term basis...the property may be classed as capital property while it is being rented. ... As outlined in paragraphs 20 and 21 of IT-331R, the lessor must acquire the property to be leased and the property must be leased before the equipment is considered to qualify for the ITC. ...

16 December 1988 Income Tax Severed Letter 7-3381- [IT-96R4, paragraphs 1 and 2 (allocation of issue price between debentures and warrants) IT-114, paragraphs 3 and 24 (deductibility of discount considered to be the equivalent of interest)] December 16, 1988 HEAD OFFICE Financial Industries Division B. Dwyer 957-2744 Subject: IT-96R4, paragraphs 1 and 2 (allocation of issue price between debentures and warrants) IT-114, paragraphs 3 and 24 (deductibility of discount considered to be the equivalent of interest) This memorandum is in response to your memorandum dated October 18, 1988, in which you asked for our comments on the above-noted matters. ...