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Once a company ceases to carry on an active business and commences to earn income from rentals, any income received by the company from the disposition of property used in the rental operation, would be considered to be income from that source. ...

The cost of purchasing books which relate to your business is generally considered to be a capital expenditure. ...

In every case, the circumstances are reviewed and carefully considered on an objective basis in accordance with the criteria set by the guidelines. ...

In our view it is intended that for pension income to be considered "not subject to Jamaican tax" it is necessary that the pension income is either exempt from Jamaican tax by virtue of its character as pension income or is eligible for a deduction that is specific to that type of income. ...

Since, in our view, these costs are deductible under paragraph 20(1)(cc) of the Act, it is not necessary to consider if the advance ruling costs should form part of the disposition cost The deduction of advance ruling costs is considered consistence with the policy purpose of the advance ruling, i.e., to encourage voluntary compliance. ...

1 August 1991 External T.I. 9114905 F- Nova Scotia R&D Tax Credit- Ontario R&D Super Allowance Unedited CRA Tags 12(1)(x), 12(1)(x)(iv), 37(1)(d), 127(11.1), 127(9) government assistance 5-911490 24(1) 19(1) Dear Sirs: Re:  Nova Scotia Research and Development (R&D) Tax Credit- Ontario R&D Super Allowance                   We are writing in reply to your letter of June 3, 1991 in which you requested a technical interpretation as to why the Nova Scotia R&D Tax Credit is considered to be government assistance for the purpose of paragraph 12(1)(x) of the Income Tax Act (the "Act") while the Ontario R&D Super Allowance is not. ...

As stated in paragraph 6 of IT-301, a payment out of a superannuation or pension fund is not considered a death benefit.  ...

In such circumstances it is possible that either the policy would be considered to have been last acquired after December 1, 1982 or the rules in subsection 12.2(9) would have application. ...

It is our opinion that where the partnership agreement for a general partnership provides that one of the corporate partners is to receive a reasonable management fee form the partnership for management services provided, generally such a fee will not constitute a business expense for income tax purposes to the partnership, but instead will be considered to be a method of distributing partnership income to that partner. ...

however, notwithstanding that legal title to the property is held by the trust, it is our view that the beneficiary may be considered to "own" his respective portion of the property as that term is used in the definition of "principal residence" contained in paragraph 54(g) of the Act. ...