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December 3, 1993 Assessment & Enquiries Personal and General Programs Section International Tax Programs D. ...

Position TAKEN: YES & YES. Reasons FOR POSITION TAKEN: The Act does not restrict deduction of dividends to co-ops. ...

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Delete the period at the end of paragraph 13 in "Proposed Transactions" and replace it with the following: ", provided that the Partnership is otherwise able to make such investment, having regard to any investment, regulatory or legislative restrictions, and subject to the General Partner's discretion to vary the requirement if necessary in the circumstances. ...

" (b) In the first sentence in the second subparagraph, insert ", as adjusted by the fair market value of such Unit at the time when the Call Option is exercised," after "during the Second Call Period will be" (c) In (ii) of the second subparagraph, delete "XXXXXXXXXX" and insert "XXXXXXXXXX" in its place (d) Insert "The total purchase price per Unit during the First Call Period and the Second Call Period, respectively, will not exceed the fair market value of the Unit when the Call Option is exercised. ...

Harding Manager, Policy & Technical Services (613) 957-8953 Trust Accounts Division Attention: Lloyd MacKay 1999-001524 Retirement Compensation Arrangements ("RCAs") This is in reply to your facsimile received December 22, 1999, in which you asked us to comment on two situations for which you have been requested to provide replies. ...

., "... it will very seldom be the case that in choosing a particular investment (an investor's(purpose is precisely to reduce as much as possible, and even refuse, so to speak, the income that the investment is likely to produce. ...

Your memo dated Dec.20 (your file # 993268 written by S. Parnanzone), stated that the T5007 amount should be included in the income of the recipient caregiver. ...

April 13, 2000 Client Services Directorate HEADQUARTERS Assessment & Collections Branch Karen Power, CA 25 McArthur Road, 1st Floor (613) 957-8953 Vanier, Ontario Attention: Betty-Ann Ward 2000-001844 XXXXXXXXXX- Taxation of Pension Benefits In response to your request of April 3,2000, we are providing you with the following insert to be included in your reply to a query raised by the above-noted taxpayer regarding the taxation of pension benefits. ...

PRINCIPALE QUESTION: Aux fins de l’alinéa b) de l’élément A du paragraphe 204.94(2) de la Loi, quel sens donne-t-on à l’expression “ régime qui ne compte aucun souscripteur”. ...