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The Technical Explanation to the Convention clearly indicates that the "... taxes not generally covered by the Convention include, in the case of United States, the estate... taxes... ...

Day (613) 957-2136 19(1) January 15, 1992 Dear 19(1) Re: Subsection 74.1(2) of the Income Tax Act (the Act) We are writing in reply to your letter of November 11, 1991, wherein you requested our opinion regarding the phrase "... from property or from property substituted" in the subject provision as it relates to the attribution of income on property transferred to a minor where a capital gain has resulted from the subsequent disposition of that property. ...

Les Delorme Business & General Chief of Audit Division Saskatoon D.O. ...

28 April 1992 Income Tax Severed Letter 9211150- Reasonableness of a Retiring Allowance PRAIRIE TAX CONFERENCE May 19 & 20, 1992 DRAFT/EBAUCHE Question 10 For a payment to be considered a retiring allowance and a deductible expense to the payer, the amount of the payment must be reasonable having regard to the length of service involved, its relationship to the remuneration received for the years of service and the value of other retirement benefits to which the employee is entitled. ...

Partnerships 7-920955- 66.1(6)(a)(iv) & (v) March 31, 1992 This request is for comments with respect to a strictly technical argument that a partnership's CEE earned under a flow-through share agreement pursuant to subparagraph 66.1(6)(a)(v) is CEE of the partnership solely by virtue of that subparagraph. ...

In previous years when the Canadian individual received a cash dividend, he was in a position to recover the tax withheld in excess of 15% of the gross amount of the dividend (i.e. 10 % of such amount) from the U.K. authorities in accordance with Articles X and XXVII (Miscellaneous Rules) of the Convention. ...

(note 3) 199 464,16 1 010,84$ Suite à ce roulement, vous indiquez qu'une réduction du capital versé permettrait de remettre à l'actionnaire 26 149,50$ (25 138,66 + 1 010,84$). ...

., commented that "... the word `payable'... is synonymous with due, a present obligation to pay... 24(1) 24(1) 14. ...

You asked us whether a T2060 is required for each former partner and whether the penalty is required to be paid by each former partner. 21(1)(a) 21(1)(b) Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch ` ...

Farrell Chief of Verifications & Collections Revenue Canada, Taxation Mississauga District Taxation Office P.O. ...