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22 October 1990 Ministerial Letter 901818 F- Definition of Foreign Property Unedited CRA Tags 206(1)(d.1) foreign property 24(1) 901818   W.C. Harding   (613) 957-8953 19(1) October 22, 1990 Dear Sirs: Re:  Definition of Foreign Property This is in reply to your letter of July 20, 1990, concerning the definition of "foreign property" as set out in paragraph 206(1)(d.1) of the Income Tax Act (the "Act"). ...

24 July 1989 Ministerial Letter 58348 F- Qualified Investments for RRSP Unedited CRA Tags 146(1) qualified investment, 206(1) foreign property, ITR 4900(1)(i)) 19(1) File No. 5-8348   A.B. Adler   (613) 957-8962 July 24, 1989 Dear Sirs: This is in reply to your letter dated July 12, 1989 in which you requested our views concerning the application of certain provisions of the Income Tax Act ("Act") and section 4900 of the Income Tax Regulations ("Regulations") to four questions raised by you. ...

8 June 1989 Ministerial Letter 58128 F- 10% Foreign Investment Rules for Self-directed RRSPs Unedited CRA Tags n/a 19(1) File No. 5-8128   Maureen Shea-DesRosierss   (613) 957-8953 June 8, 1989 Dear Sirs: Re:  10% Foreign Investment Rules for Self-Directed Registered Retirement Savings Plans This is in reply to your letter of May 16, 1989 wherein you request clarification of the 10% foreign investment rules for Self-Directed Registered Retirement Savings Plan ("RRSP"). ...

26 April 1990 Ministerial Letter 59388 F- Limitation Re Personal Services Business Expenses Unedited CRA Tags 18(1)(p), 125(7) personal services business 19(1) File No. 5-9388   R.B. Day   (613) 957-2136 April 26, 1990 19(1) We are writing in reply to your letter of January 8, 1990, wherein you requested our interpretation of paragraph 18(1)(p) of the Income Tax Act as it relates to the following hypothetical situation. 1.      ... Since subparagraph 18(1)(p) refers to "the salary, wages or other remuneration paid in the year"... it is clear that a deduction under paragraph 18(1)(p) is not available for that year. 2.      ...

13 July 1989 Ministerial Letter 58288 F- Transfer from RRSP Unedited CRA Tags 60(1), 146(1) retirement income, 146(2)(b)(ii) 19(1) File No. 5-8288   A.B. Adler   (613) 957-8962 July 13, 1989 Dear Sirs: This is in reply to your letter dated June 26, 1989, and is further to yours of May 5 and ours of May 18, 1989, in which you requested our views concerning the application of paragraphs 60(1) and 146(1)(i.1) of the Income Tax Act ("Act"). ... You advised that several financial institutions may be either (i)     issuing term certain annuities that do not comply with the provisions of section 146 of the Act, or (ii)     transferring commutation payments into annuities that do not comply with the provisions of paragraph 60(1) of the Act. ...

29 May 1990 Ministerial Letter 59748 F- Deductibility of Lease Cancellation Payments to Tenants Unedited CRA Tags 20(1)(z), 20(1)(z.1) 24(1) File No. 5-9748   T. Murphy   (613) 957-2747 19(1) May 29, 1990 Dear Sirs: Re:  Technical Interpretation of paragraphs 20(1)(z) and 20(1)(z.1) of the Income Tax Act (the "Act") This is in reply to your letter of March 8, 1990 wherein you requested our views on the deductibility of a lease cancellation payment made to tenants by a taxpayer, to obtain vacant possession of recently acquired land and buildings, with the intention of destroying the existing buildings and constructing a new building. ... Therefore, provided the amount is reasonable: (i)     that portion of the lease cancellation payment which relates to the building would generally be deductible by the landlord in the year the building was demolished pursuant to paragraph 20(1)(z.1) of the Act to the extent of the amount thereof (or in the case of capital property, 3/4 of the amount thereof) that was not deductible by him in computing his income for any preceding year pursuant to paragraph 20(1)(z) of the Act; and  (ii)     that portion of the lease cancellation payment which relates to the land would generally be deductible by the landlord in accordance with the calculation in paragraph 20(1)(z) of the Act. ...

6 September 1989 Ministerial Letter 73928 F- Nature of Payments Unedited CRA Tags 18(1)(a), 56(2), 15(1), 110(1)(a), 5(1)   September 6, 1989 Sudbury District Office Specialty Rulings   Directorate Attention:  A.F. ... Eisner   Tel. (613) 957-2138   File No. 7-3928 Subject: 24(1) This is in reply to your memo of May 17, 1989 concerning the tax treatment of certain payments made by the Taxpayer in 1987 and 1988. ...

18 July 1990 Ministerial Letter 74508 F- Penalty for Repeated Failure to Report Unedited CRA Tags 163(1)   July 18, 1990 Current Amendments and Specialty Rulings Regulations Division Directorate   J.D. ... Bryson 957-2104 Acting Director   7-4508 Subsection 163(1) Penalty This is in reply to your memorandum dated November 6, 1989, wherein you requested our comments on the interpretation of subsection 163(1) of the Act in light of the views expressed by the Department of Finance. 21(1)(b) 23 M.G. ...

X, the best and highest value for the property was derived from its use in the business of farming. 4.      ... X.      It is our view that irrespective of the basis on which Mr. X  may have determined the amount that he was willing to pay for the property, whether the farmland value or some other value, the property would be a capital property of Mr. ... Further, section 45 may be irrelevant because a CRP is not a capital property.  2.      ...

This amount would represent a substantial claim against the company's asset. 3.      ... B are not related persons as defined in subsection 251(2) of the Act. 4.      ... B have acquired the necessary number of shares to control Holdco. 2.      ...