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XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to reply to your letter of March 24, 1999, concerning a newspaper article in The Vaily Townsman on December 2, 1998, which commented on observations made by the Auditor General regarding Revenue Canada's processing of income taxes withheld at source. ...

the actual documentation of the programme indicates that the employees are required to pay 100% of the cost of the plan, 2.      ...

Further, as indicated in schedule 1 to the 1989 Individual Income Tax Return for residents of Ontario, taxable income is generally subject to the federal surtax and to Ontario income tax. 2.      ...

Holdco is a Canadian-controlled private corporation with a wholly-owned subsidiary, Opco, which is a small business corporation as defined in subsection 248(1) of the Act. 2. ...

While the order confers certain tax relief on various individuals, section 3(3) of the Privileges and Immunities Act, under which the Order was issued states:      "Nothing in any order made under subsection (2) shall exempt a Canadian citizen residing or ordinarily resident in Canada, from liability for any taxes or duties imposed by any law of Canada. ...

Facts (from your file) 1)      2)      3)     24(1) 4)      5)      6)      Issue:  Can each trust obtain the $40,000 exemption referred to in subsection 127.53(1) or must it be shared per subsection 127.53(2) and (3). ...

Based on our interpretation of the Article and the intention of the Convention, we are of the view that a dividend from the NRO to Swedenco in the situation set out in paragraph 2 above would probably not be exempt, by virtue of paragraph 2(d)(i) of Article 23 of the Convention, from Swedish tax.  ...

For clarity, the Plan should note that a taxation year is a calendar year and in consequence, any amounts earned in a particular calendar year must be paid out by December 31 of that year. 2.     24(1) This provision may indicate that the main purpose of the Plan is not to permit the employees to fund a leave of absence from employment but rather to defer income taxes. ...

This exception is an administrative concession by the Department and will not be available unless all of the six conditions set out by the Department, as restated hereunder, are satisfied. 1)     The corporation's only objective is the holding of property for the personal use or enjoyment of the shareholder. 2)     The shares of the corporation are held be an individual or person (other than a corporation) related to the individual. 3)     The only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. 4)     The shareholder would be charged with all the operating expenses by the corporation, with the result that the corporation would show no profit or loss with respect to the property on any of its returns. 5)     The corporation acquired the property with funds provided solely by the shareholder and not by virtue of his holdings or that of a related person in any other corporation. 6)     The property must be acquired by the corporation on a fully taxable basis (that is, without the use of any of the rollover provisions of the Act). ...

2.     Is it eligible for a direct "roll-over" to an RRSP in the same tax sheltered manner as a pension fund transfer or return of pension contributions? ...