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For the purpose of this technical interpretation you have assumed the following facts: 1.          ... All of the director's meetings for Albertaco will take place at its head office situated on the Reserve. 5.      ... In carrying on business off the Reserve, the Partnership may use some of its equipment outside the Reserve. 7.      ...

B is a subcontractor who is not prepared to enter into a contract of employment with A Corp. 3.      ... The remaining common shares would be held by B. 4.     In addition to the common shares authorized by AB Corp, there would be two classes of special shares, Class A and Class B. 5.     Class A special shares would be issued to A Corp and Class B special shares would be issued to B. 6.      ...

Kauffman   957-8953   File No. 7-4188 SUBJECT:  Version 10 of draft IT-359R3 In reply to a memorandum from Mr. ... Delorey of your Division dated July 27, 1989 we have the following comments on this version of IT-359R3: 1)     Paragraph 12- This paragraph generally reflects our approach.  ... Presently there is a "for example" within a "for example". 2)     Paragraph 11(b)- typo second word, second line. 3)     Comments from our memorandum of July 19, 1989 are otherwise correctly reflected. ...

XXXXXXXXXX •     It was not intended to limit the consultations in any way. ...

26 June 1989 Ministerial Letter 32428- Déductibilité des intérets Unedited CRA Tags 20(1)(c)   19(1) File No. 3-2428   (613) 957-8971   A. ... Votre dépôt au montant de 325.00 $ vous sera retourné  son pli distinct. ...

16 October 1989 Ministerial Letter 58298 F- Disposition of Capital Property Unedited CRA Tags 53(1)(h), 20(1)(c), 18(2), 18(1), 18(1)(a)   October 16, 1989   5-8298   Dear Sirs: Re: Our file 5-7548 We are writing in reply to your letter of June 19, 1989 in which you asked for our comments concerning the disposition of capital property of a taxpayer to whom the provisions of paragraph 53(1)(h) regarding interest on undeveloped land are not available. ...

30 November 1989 Ministerial Letter 32028- Demande de décision anticipée Unedited CRA Tags n/a 19(1) Your File No. 88-02-01355   Our File No. 3-2028   A. Simard   (613) 957-8981 Le 30 novembre 1989 Monsieur, Objet:  Demande de décision anticipée 24(1) La présente fait suite à l'entretien téléphonique (Simard 19(1)  du 2 novembre 1989 relativement à votre demande de décision anticipée du 21 novembre 1988 pour le compte du contribuable mentionné plus haut, par lequel vous exprimez le désir de retirer cette demande.  ...

24 August 1990 Ministerial Letter I3858 F- Large Corporations Tax on Non-profit Organizations Unedited CRA Tags n/a   August 24, 1990 Rulings Directorate Current Amendments and   Regulations Division Attention: B. ... Murray Director, Business & 957-2079 General Division   I-3858 Large Corporations Tax to Non-Profit Organizations Enclosed is a copy of a letter to the Department of Finance along with a copy of a letter from Len Farber of Finance to us requesting our views on the application of the Large Corporations Tax on non- profit organizations. ...

30 June 1989 Ministerial Letter 58138 F- Application of GAAR to the Acquisition of an Employee's Shares Purchase Plan Unedited CRA Tags 84(3), 84.1, 89(1) paid-up capital, 89(1) private corporation, 183.1, 245 19(1) File No. 5-8138   Firoz Ahmed   (613) 957-2092 June 30, 1989 Dear Sirs: Re:  Section 245 of the Income Tax Act (Canada) (the "Act") This is in response to your letter of April 11, 1989, in which you requested our views on the application of the general anti-avoidance rule ("GAAR") contained in section 245 of the Act to the acquisition of an employee's shares purchase plan in the hypothetical fact situation described below. ... You have also requested our opinion as to the application of GAAR to the following variations of such an acquisition: (1)     the Purchased Shares are acquired by Opco shortly after their acquisition by Holdco; or (2)     the acquisition of the Purchased Shares by Holdco is funded by a dividend from Opco to Holdco on a separate class of shares owned by Holdco. ... The following statement is contained in item 25 of Information Circular 88-2:      Provisions, such as those mentioned above (sections 84.1  and 183.1, among others) indicate the circumstances in which amounts received by a shareholder of a corporation from the corporation on a disposition of shares or other property are to be accounted for as a dividend.  ...

Income Tax Convention Unedited CRA Tags Article XIII(8), Canada/US Treaty   September 28, 1990 TO: FROM: International Audits Division Technical Publications L.W. Mulligan Division Competent Authority Section Technical Review Section   S. ... Income Tax Convention in support of his request for the remission of the tax liability on the gain.     ...