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14 June 1993 External T.I. 9317470 F- Interest Expense- Accounts Payable Unedited CRA Tags 20(1)(c)   1993 CANADIAN PETROLEUM TAX SOCIEY ROUND TABLE INTEREST EXPENSE QUESTION 36 Interest is deductible pursuant to 20(1)(c)(ii) in respect of an amount payable for property related to a business. 20(1)(c)(ii) is presumably considered necessary by the Department of Finance on the grounds that an unpaid purchase price is not "borrowed money", so that any interest charged by suppliers on overdue accounts would not be deductible, but for 20(1)(c)(ii). ...

DRAFT Revenue Canada Round Table Canadian Petroleum Tax Society June, 1995 Question No. 11 AMALGAMATIONS Does the Department agree that according to the decision of the Federal Court of Appeal in Pan Ocean Oil, 94 DTC 6412, Canadian resource property is considered to be "acquired" in a long-form amalgamation for section 66.7 purposes? ...

Would such installation activity be considered as "manufacturing or processing" ("M & P") under section 125.1 of the Income Tax Act (the "Act")? ...

In our opinion a Canadian resident taxpayer who is a member of a partnership which carries on a business in a foreign country would be considered to be carrying on that business in that foreign country and would be entitled to claim his share of the partnership business-income tax paid as a foreign tax credit pursuant to subsection 126(2) of the Act. ...

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 24 of Information Circular 70-6R dated December 18, 1978. ...

However, since the corporate restructuring relates to a factual situation and proposed transactions that can only be considered within the ambit of an advance income tax ruling request, you may wish to re-submit your request for approval in a formal request for an advance income tax ruling. ...

Murphy   (613) 957-2747   EACC9356   3-901514 SUBJECT:  Advance Income Tax Ruling 24(1) We recently considered an advance income tax ruling request (copy attached)   24(1) While we refused to rule on this proposed transaction described in the ruling request, it is possible that 24(1) and 24(1) may proceed with the same or similar transaction without an advance income tax ruling. ...

It is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. ...

However we are awaiting representations from other interested parties and would prefer to respond to the issues you have raised after all concerns are presented and considered. ...

As explained to 19(1)   in our telephone conversation of July 20, 1989 the issues involved in this case are presently being considered by officers of our Vancouver District Office, and we are therefore unable to comment on any aspects of the case at the present time. ...