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2 February 1990 Ruling 32703 F- Advance Income Tax Ruling Request Unedited CRA Tags n/a 19(1) File No. 3-2703   M. Eisner   (613) 957-2138 February 2, 1990 Re: 24(1) Advance Income Tax Ruling Request In your letter of January 2, 1990, you advised us that certain information, which we require in order to proceed with our consideration of your advance income tax ruling request, will not be available until June, 1990.  ...

11 September 1995 Ruling 9521423- TAXATION OF PRE-DECEMBER 2, 1982 INSURANCE POLICIES Unedited CRA Tags 148(1) 148(9) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... We confirm that life insurance policies issued prior to December 2, 1982 do enjoy limited tax-favoured treatment not available with respect to policies issued after December 1, 1982. For example pre-December 2, 1982 policies are not generally subject to tax upon the annual accrual of investment income within a policy nor are they subject to tax on the proceeds received on the consequence of the death of an individual whose life was insured under the policy. ...

2 June 1992 Ruling 920703A F- Capital Gains Exemption- Dividend Non-Payment Unedited CRA Tags 110.6(1) qualified small business corporation share, 110.6(8) SUBSECTION 110.6(8) The questions dealt with how the provision applies to a particular scenario. SCENARIO Year 1, CS subscribed for a nominal amount by MR.X Year 5, CS of MR.X fmv $1 million Year 6, PS subscribed for by MR.X Year 8, PS redeemed Year 9, CS of MR.X fmv $2 million, value attributed to non-payment of PS dividends is $200,000 a)      Does 110.6(8) apply if a $400,000 capital gain is triggered and a related capital gains deduction claimed? ... For example in this scenario the fmv related to the non payment of dividends could have been $1.6 million ($2 million- $400,000) before the capital gains deduction would have been effected here. b)     No answer required as the answer to a is the provisions do not apply.  ...

2 February 1990 Ruling 74673 F- Publication of Advance Tax Ruling No. 3-2055 Unedited CRA Tags n/a   February 2, 1990 Publications Division Financial Industries Division Mr. ...

2 February 1990 Ruling I-3500 F- Compliance Research Projects #90.1 and 90.2 Unedited CRA Tags n/a   February 2, 1990 Mr. ...

2 October 1989 Ruling 89M10481 F- Oil and Gas Taxation in Canada Course Unedited CRA Tags n/a   October 2, 1989 CALGARY DISTRICT OFFICE HEAD OFFICE Basic Files Section Resource Industries Oil and Gas Industry Studies Section   Jim Gauvreau John Kurrant (613) 957-8953 Subject: Oil and Gas Taxation in Canada Course At your request, I am writing to inform you of the names of those who will be participating on behalf of Rulings in the above-captioned course on October 17th and 18th, 1989.  ...

2 June 1989 Ruling 57633 F- Source of Income- Non-Competiton Agreement Unedited CRA Tags 126(1), 42   19(1) File No. 5-7633   S. Leung   (613) 957-2116 June 2, 1989 Dear Sirs: Re:  Source of income for purpose of Subsection 126(1) of the Income Tax Act (Canada) (the Act) This is in reply to your letter of March 3, 1989 wherein you requested our opinion as to whether the consideration to be received by your client with respect to a non-competition agreement would be considered foreign source income for purposes of subsection 126(1) of the act in the following situations: 1.      ... The sale will take place in the U.S. 2.     The purchaser has requested that your client enter into an agreement not to compete with a subsidiary or other persons related to the purchaser in any business similar to that of the subsidiary carried on in the U.S. for a fixed number of years.  ...

2 November 1989 Ruling 58633 F- Partnerships Unedited CRA Tags 54.2, 96 19(1) File No. 5-8633   R.B. Day   (613) 957-2136 November 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. ...

2 November 1989 Ruling 5-8721- Demande d'opinion en matière d'impôt Unedited CRA Tags n/a 19(1) File No. 5-8721 C. Thériault (613) 957-8978 Le 2 novembre 1989 Monsieur, Objet: 19(1) Demande d'opinion en matière d'impôt sur le revenu La présente fait suite à votre conversation téléphonique du 17 octobre 1989 avec 19(1) relativement à votre demande d'opinion du 19 septembre 1989 pour le compte du contribuable mentionné ci-dessus. ...

2 January 1990 Ruling F3343 F- Attribution Rules Unedited CRA Tags 74.5(7), 74.4 January 2, 1990 Mr. ...