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Office Y.S. 9226008 Central Records Author / Section Chief District Office? Research File Taxpayer's File Return to Specialty Rulings, Room 303, Met.   ... Yours sincerely, Otto Jelinek c.c:      The Honourable Don Mazankowski, Deputy Prime Minister, President of the Queen's Privy Council for Canada and Minister of Agriculture G. ...

Mancino, Director Division   A. Humenuk   957-2135   File No. 7-3728 Subject:  Taxable Benefits Manual- Automobile Benefits We are responding to your round trip memorandum of March 9, 1989, concerning the technical accuracy of the above noted manual.  ... If the amount is not an expense related to the operation of the automobile, the standby charge would be $270- 200 = $70 and the operational benefit calculated under subsection 6(2.2) would be 1/2 * 270- 0 = $130 for a total taxable benefit of $200. 20)     Page 20, Paragraph 44, "Period":  We think that the word "discrete" should be replaced with the word "finite". 21)     Page 20, Paragraph 45:  As explained in comment 11 above, an allowance does not include a reimbursement. 22)     Page 20, Paragraph 46: A)     Second sentence:  We suggest that the phrase "service men" be replaced with "service personnel". B)     A typographical error was noted in this sentence as the word "sales" has been duplicated. 23)     Page 21, Paragraph 50 & 51: A)     As subparagraphs 6(1)(b)(x) and (xi) apply to subparagraphs 6(1)(b)(v), (vi) and (vii.1) and not to subparagraph 6(1)(b)(vii) of the Act, we think you should amend the references accordingly. ...

5 September 1989 Ministerial Letter 32608 F- Settlement Unedited CRA Tags 245   September 5, 1989 FILE- Section 245 Small Business and   General Division   P.D. Fuoco   File No. 3-2608 Subject: Advance Income Tax Ruling 19(1) The attached rulings concern a standard structured settlement for which the Department has an established position if the conditions set out in paragraph 5 of IT-365R2 are satisfied. ...

Or, The 0xford English Dictionnary (2e édition) le définit comme suit:      agent-general, The official representative of a non-sovereign country or state in the capital city of a sovereign state; [specifically] a representative of: (i) the British Crown Colonies (also the Dominion of Canada) in London; (ii) an Australian state or Canadian (...) ... À     partir de cette définition 24(1).../2 24(1) Nous espérons que nos commentaires vous seront utiles et nous vous prions d'agréer l'expression de nos sentiments distingués. ...

7 November 1989 Ministerial Letter 58698 F- Registered Retirement Savings Plan Unedited CRA Tags 212(1)(l), 212(1)(q), 248(1) annuity 19(1) File No. 5-8698   D.S. Delorey   (613) 957-3495 November 7, 1989 19(1) This is further to your telephone conversation with the writer on September 25, 1989 and in reply to your letter of September 19 concerning your plan to again 19(1) 24(1) With respect to the planned transfer of your pension plan funds to an RRSP, proposed legislation as released by the Department of Finance in March 1988 provides for a tax-free transfer to an RRSP of a lump sum amount from one plan to the other. ... With respect to the word "annuity", subsection 248(1) of the Act states that      "'annuity' includes an amount payable on a periodic basis whether payable at intervals longer or shorter than a year and whether payable under a contract, will or trust or otherwise". ...

20 March 1990 Ministerial Letter 59228 F- Capital Gains Exemption Unedited CRA Tags 110.6(8), 85(1) 19(1) File No. 5-9228   M. Vallée   (613) 957-2093 March 20, 1990 Dear Sirs: Re:  Subsection 110.6(8) of the  Income Tax Act (the "Act") This is in reply to your letter dated December 7, 1989, whereby you requested our opinion regarding the applicability of subsection 110.6(8) of the Act in a hypothetical situation that can be summarized as follows:      An individual, Mr. ...

21 September 1990 Ministerial Letter 900628 F- Automobile Allowances Unedited CRA Tags 6(1)(b) 24(1) 900628   J.A. Szeszycki   (613) 957-2103 19(1) EACC9626 September 21, 1990 Dear Sirs: Re:  24(1) Automobile Allowances This is in reply to your letter dated March 1, 1990 in which you enclosed a copy of a previous letter addressed to us dated September 14, 1989.  ... Yours truly, for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.       ...

17 April 1990 Ministerial Letter 59828 F- Winding-up of a Trust Unedited CRA Tags 12.2, 54 disposition, 104(4)(b), 107(2), 245(3), 245(2), 19(1) File No. 5-9828   D.S. Delorey   (613) 957-3495 April 17, 1990 Dear Sirs: Re:  Winding Up of a Trust This is in reply to your letter of March 7, 1990 concerning the transfer of a life insurance policy from one trust to another trust. ... However, subparagraph 54(c)(v) of the Act provides that a disposition for the purposes of the Act does not include      "any transfer of property by virtue of which there is a change in the legal ownership of the property without any change in the beneficial ownership thereof... ...

26 June 1990 Ministerial Letter 900688 F- Purification of a Corporation Unedited CRA Tags 248(10), 55(3), 55(4), 55(2)   24(1) File No. 900688   M.P. Sarazin   (613) 957-2125 Attention: 19(1) June 26, 1990 Dear Sirs: Re:   Request for an opinion on the potential "purification" of a corporation This is in reply to your letter dated May 4, 1990 in which you requested our interpretation as to the application of various provisions of the Income Tax Act (the "Act") to the following situation you described. 24(1) 24(1) It appears that the interpretation you seek relates to a specific taxpayer and, therefore, we bring to your attention Information Circular 70-6R dated December 18, 1978 issued by Revenue Canada, Taxation and the related Special Release thereto.  ... You have stated that the purpose of the transactions outlined above is  24(1) in this regard, we would like to point out that (i)     subsection 248(10) of the Act contains an extended definition of the term "series of transactions or events", and (ii)     it is our view that a preliminary transaction will form part of a series of transactions referred to in subsection 248(10) of the Act if, at the time the preliminary transaction is carried out, the taxpayer has the intention to implement the subsequent transactions constituting the series and the subsequent transactions will be part of a series even though at the time of the completion of the preliminary transaction the taxpayer either had not determined all of the important elements of the subsequent transactions including, possibly, the identity of other taxpayers involved, or had lacked the ability to implement the subsequent transactions.      24(1) In addition, you have requested our views in the circumstances where 24(1) is owned by more than one shareholder and they are not related. ...

.- Adverse Decisions Unedited CRA Tags 110.4, 85   August 2, 1990 Appeals and Referrals Division Technical Publications Ms L.C. Tremblay Division Director Technical Review Section Bernhard Buetow Attention:  Josephine Yu Tel. 957-9226   8-901648      EACC9236 Re: Adverse Decision The Queen v. ...