17 January 1991 External T.I. 9015405A F - Capital Gains Exemption - Definition of "Investment Income"

By services, 18 January, 2022
Official title
Capital Gains Exemption - Definition of "Investment Income"
Language
French
CRA tags
56(1), 110.6(1)
Document number
Citation name
9015405A
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631090
Extra import data
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"field_external_guid": [],
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"field_release_date_new": "1991-01-17 07:00:00",
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Main text

5-901540

Subject: Subsection 110.6(1) "Investment Income" - 1990 Technical Bill

We wrote to you on January 11, 1989 suggesting that annuity income did not represent income from property for the purposes of the definition of "investment income" in subsection 110.6(1) of the Act.

We have recently had occasion to reconsider this matter and it is now our view that income taxed under paragraphs 56(1)(d) to (d.2) of the Act is income from property for the purposes of the Act.  We enclose for your information copies of recent correspondence relevant to this issue

21(1)(b)

Director GeneralRulings DirectorateLegislative & Intergovernmental Affairs Branch