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It is our view that where the modular wiring system is owned by a taxpayer who also owned the building, the modular wiring system would be considered an integral part of the building necessary for effective functioning and should be included in either Class 1, 3 or 6 of Schedule II of the Income Tax Regulations (the Regulations). ...

The opinions expressed herein and in our letter of September 12, 1990 are not advance income tax rulings and, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990, are not considered binding on the Department. ...

It is, however, our view that a group of persons will be considered as having collectively acquired control where there is evidence that they have a common link or interest or they act together to control the corporation. ...

You inquired if the property, would be considered to be Qualified Farm Property under each scenario outlined above. ...

Based on the scenario described above, you have asked the following questions: a) In the first year of operation in Canada of the joint venture, would the non-resident corporate member of the joint venture (hereinafter referred to as “non-resident”) be considered to be a new corporation and therefore instalments would not be required in that year? ...

7 October 1991 Income Tax Severed Letter- Strike Pay Unedited CRA Tags 3(a), 149(1)(k) Dear Sirs: This is in reply to your letter of August 13, 1991 in which you requested a technical interpretation on whether or not amounts received by union members out of a strike fund can be considered to be "income from a source" for the purposes of paragraph 3(a) of the Income Tax (the Act). ...

XXX Subsection 85(7.1) applies at the discretion of the Minister where it is considered just and equitable to permit a late filing or amendment. ...

Paragraph (e) of the QSBC share definition in subsection 110.6(1) of the Act provides that where, at any time in the 24 month period ending at the determination time, the share was substituted for anther share, the share shall be considered to have met the requirements of that definition only where, inter alia, the other shares was not owned by an unrelated person or partnership throughout that part of the 24 month period ending at the determination time that ends at the time of substitution. ...

Capital cost allowance with respect to the property may not be claimed while a subsection 45(2) election is in force since the property is considered a personal use property. ...

C) With respect to inhabiting a dwelling, it is our general view that if a loan is used by an individual to acquire a seasonal residence, the dwelling will be considered to be acquired for an individuals habitation if the individual "ordinarily inhabits" the residence within the meaning of that term as set out in paragraph 9 of IT-120R3. ...