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Specifically, you indicate that you have XXXX You request our view as to whether or not the two businesses would be considered to be "similar businesses" for the purpose of the definition of "replacement property" under subsection 14(7) of the Income Tax Act ("the Act"). ... Hence, in the situation described, it is our opinion that the restaurant business and the hotel business would probably be considered to be "similar businesses" for the purpose of paragraph. 14(7)(b) of the Act. ...

In paragraph 12 of Interpretation Bulletin IT-145R, the Department has indicated that the drying of lumber in kilns before shipment is considered to be a manufacturing or processing activity. In our view, the fact that this is the only activity carried out by a taxpayer will not, in and by itself, result in the activity not being considered as manufacturing or processing. ...

As a result some grants formerly considered non-taxable are now taxable. We must therefore inform you that grants under the Ontario Farm-Start Program are taxable on receipt unless they can be considered to reduce the cost or capital cost of property acquired. ...

When a taxpayer transfers property to a taxable Canadian corporation pursuant to subsection 85(1) of the Income Tax Act (Canada) (the "Act") and receives shares of the corporation having an aggregate fair market value less than the fair market value of the property transferred, he is considered to have conferred a benefit on the corporation pursuant to paragraph 85(1)(e.2) of the Act if the corporation was related to him. ... If the fair market value of the common shares immediately after the transfer is not less than the fair market value of the transferred property immediately before the transfer, no benefit is considered to have been conferred on the transferee. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ...

Robb 613-957-2744 January 29, 1990 19(1) Re: Paragraph 84.1(1)(b) and subparagraph 129(1)(a)(i) of the Income Tax Act (the "Act") We are writing in response to your letter of December 15, 1989 in which you requested our views concerning the question of whether a deemed dividend under paragraph 84.1(1)(b) is considered to be a taxable dividend for the purposes of subparagraph 129(1)(a)(i) of the Act. In our view, a deemed dividend under paragraph 84.1(1)(b) would be considered to be a taxable dividend paid for the purposes of subparagraph 129(1)(a)(i) of the Act, provided that subsection 129(1.2) was not applicable. ...

As a result some grants formerly considered non-taxable are now taxable. We must therefore inform you that grants under the Ontario Farm- Start Program are taxable on receipt unless they can be considered to reduce the cost or capital cost of property acquired. ...

Baldwin (613) 957-3499 19(1) January 25, 1991 Dear Sirs: This is in reply to your letter of July 20, 1990 asking if the proceeds on a life insurance policy would be considered substituted property such that the attribution rules would apply. Based on the facts given in your letter and on a subsequent telephone conversation (Baldwin 19(1) Is our opinion that the proceeds on the life insurance policy would be considered to be substituted property. ...

The Department's position as set out in paragraph 2 of Interpretation Bulletin IT-131R2 is that a convention held during an ocean cruise is considered as being held outside the territorial scope of the organization. Since subsection 20(10) of the Income Tax Act requires the convention to be held at a location that can reasonably be regarded as consistent with the territorial scope of the organization it is our view that the expenses relating to a convention that your clients propose to hold during an ocean cruise (a cruise to Alaska is considered an ocean cruise) would not be deductible by the members. ...

We are of the view that an investment which is not a foreign property (within the context of subsection 206(1)) in itself would not be considered foreign property should it be denominated in U.S. dollars. Furthermore, investment income and proceeds of disposition of such investments are not considered to be foreign property provided they are immediately converted to Canadian currency or promptly used to acquire property that is not foreign property. ...

Day (613) 957-2136 NOV- 2 1989 19(1) We are writing in reply to your letter of August 30, 1989, wherein you requested our views as to whether or not a partnership would be considered a person for the purposes of section 54.2 of the Income Tax Act. ... " In view of the above, it is our opinion that a partnership would not be considered a person for purposes of section 54.2. ...