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2 May 1990 Ruling 59573 F- Agreement Between Partnership and Non-Arm's Length Person Unedited CRA Tags 78, 96, 150 19(1) File No. 5-9573   R.A. Primeau   (613) 957-2060 May 2, 1990 19(1) This is in reply to your letter of February 6, 1990.  ...

2 January 1990 Ruling HBW4131U3 F- Extension of Period of Detachment under Canada-U.S. Tax Agreement Unedited CRA Tags n/a 19(1) HBW 4131-U3   Al Watson   (613) 957-2072 January 2, 1990 Dear 19(1) This is to request your concurrence in granting an extension of the sixty-month period of detachment under Article V(2)(a) of the Canada-United States Social Security Agreement in the following case: CANADIAN EMPLOYER: 19(1) EMPLOYEE: The initial period covered by the certificate will conclude on December 31, 1989. ...

2 March 2001 Ruling 2001-0070233- Collective Agreement, PBSA Unedited CRA Tags 8500(1) 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. ... Sarazin, CA March 2, 2001 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request- XXXXXXXXXX This is in reply to your letter of February 7, 2001, requesting an advance income tax ruling on behalf of the above-noted taxpayer. ... (a) As noted in paragraph 2 of IC 70-6R4, an advance income tax ruling is a written statement given by the Directorate to a taxpayer stating how the Agency will interpret and apply specific provisions of existing Canadian income tax law to a definite transaction or transactions which the taxpayer is contemplating. ...

2 November 1989 Ruling 58501 F- Investment Income from Associated Corporation Deemed to be Active Business Income Unedited CRA Tags 129(6), 256(2), 125 19(1) File No. 5-8501   M. Vallée   (613) 957-2093 November 2, 1989 Dear Sirs: Re:  Subsection 129(6) of the Income Tax Act Technical Interpretation This is in reply to your letter dated August 3, 1989, wherein you requested our opinion in relation to the interpretation of subsection 129(6) of the Income Tax Act (the "Act") in the following hypothetical situation. ...

2 August 1991 Ruling 911841 F- Situs of Corporation "Off" Indian Reserve Unedited CRA Tags 81(1)(a)                                              August 2, 1991   Audit Applications Division                  Business and General K.R. ...

2 October 1989 Ruling 58541 F- Transfer of Retiring Allowance to an RRSP Unedited CRA Tags 60(j.1) 19(1) File No. 5-8541   D.S. Delorey   (613) 957-3495 October 2, 1989 Dear Sirs: This is in reply to your letter dated July 27, 1989 concerning the transfer of a retiring allowance to a Registered Retirement Savings Plan ("RRSP") under paragraph 60(j.l) of the Income Tax Act (the "Act"). ...

2 August 1989 Ruling 58263 F- Treatment of Non-residents in Certain Situations Unedited CRA Tags n/a 19(1) File No. 5-8263   K.B. Harding   (613) 957-2129 August 2, 1989 19(1) This is in reply to your letter of June 7, 1989 wherein you requested our opinion with respect to the treatment of non-residents in the following circumstances. 1.      ... 2.     If the house mentioned above is gifted to a non-resident before death, is it then necessary for the non-resident to pay capital gains tax when it is sold?  ...

2 May 1991 Ruling 9108473 F- Draft Legislation on the Income Taxation of Trusts Unedited CRA Tags n/a 3-910847 Dear Sirs: Re:  24(1) Advance Income Tax Ruling Request This is in reply to your letter of March 11, 1991 wherein you requested the above noted ruling request. ...

2 July 1991 Ruling 911323 F- Employee Relocation Assistance Unedited CRA Tags 6(1)(b), 5(1), 80.4(1), 6(9) Dear Sirs: Re:  Employee Relocation Assistance This is in reply to your letter dated May 9, 1991 wherein you requested our opinion on the tax consequences with respect to employer paid relocation assistance. ... In addition, the Department would not assess a benefit in situations where the employee receives a low or no interest loan or a mortgage interest subsidy from the employer for the outstanding mortgage on the old home for the period between the purchase of the new home and the sale of the old home. 2.      ...

2 February 1994 Ruling 9337623 F- Two Spouses at Same Time Unedited CRA Tags 146.3(1) registered retirement income fund, 146.3(6.1), 252(4) RULINGS DIRECTORATE CORRESPONDENCE SUMMARY PRINCIPAL ISSUES: Can a deceased annuitant have two spouses at the same time for purposes of subsection 146.3(6.1) and paragraph 146.3(1)(b.01). ...