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19 April 1990 Ministerial Letter 59428 F- Butterfly Reorganizations- Whether "Property has Become Property of the Particular Corporation" Unedited CRA Tags 55(3)(b) 19(1) File No. 5-9428   Firoz Ahmed   (613) 957-2092 April 19, 1990 Dear Sirs: Re:  Paragraph 55(3)(b) of the Income Tax Act (Canada) (the "Act") This is in response to your letter of January 19, 1990 in which you requested our views as to whether "property has become property of the particular corporation" within the meaning of paragraph 55(3)(b) of the Act in the situation described below. ...

26 June 1989 Ministerial Letter 58158 F- Withholding Tax on Payments made to Non-Residents Unedited CRA Tags 212(1)(d)(vi) 19(1) File No. 5-8158   K.B. Harding   (613) 957-2129 June 26, 1989 Dear Sirs: This is in reply to your letter of May 26, 1989 concerning the obligation to withhold tax on payments made to non-residents in respect of a copyright and in respect of the production or reproduction of computer programs prior to June 8, 1988. ...

15 November 1989 Ministerial Letter 58958 F- Qualified Small Business Corporation Share Unedited CRA Tags 110.6(1) qualified small business corporation share 19(1) File No. 5-8958   S. Leung   (613) 957-2116 November 15, 1989 Dear Sirs: Re:  Qualified Small Business Corporation Share ("QSBC Share") We are writing in response to your letter of October 11, 1989 wherein you requested our opinion on whether, in the situation described below, the time during which the person held the shares of a corporation would be included in meeting the 24 month test pursuant to paragraph (b) of the definition of "QSBC Share" in subsection 110.6(1) of the Income Tax Act (the "Act"). ...

23 January 1990 Ministerial Letter 59098 F- Employee Share Purchase Plan Unedited CRA Tags 7, 32.1 19(1) File No. 5-9098   W.C. Harding   (613) 957-3499 January 23, 1990 Dear Sirs: Re:  Employee Share Purchase Plans This is in reply to your letter of November 15, 1989 wherein you requested our consideration of a proposed model share purchase plan. ...

2 October 1990 Ministerial Letter 902538 F- Donation made by Vendor Unedited CRA Tags n/a 24(1) 902538   C. Tremblay   (613) 952-1361 19(1) October 2, 1990 Dear Sirs: 24(1) This is in reply to your letter of September 13, 1990, concerning the offers to purchase the above named property. ...

21 December 1989 Ministerial Letter 58678 F- Wage Loss Replacement Plans Unedited CRA Tags n/a 19(1) 5-8678   A. ... the actual documentation of the programme indicates that the employees are required to pay 100% of the cost of the plan, 2.     the premium which is remitted by the employer is added to the employee's income in the manner of salary and wages paid at the time the premium is paid, and 3.      ...

6 July 1989 Ministerial Letter 58258 F- Deferred Salary Leave Plan Unedited CRA Tags 6801 19(1) File No. 5-8258   W.C. Harding   (613) 957-3499 July 6, 1989 Dear Sirs: Re:  Deferred Salary Leave Plan (the "Plan") This is in reply to your letter of June 6, 1989, referred to us by our Assessing Directorate, requesting a ruling in respect of the above noted plan for the purposes of the definition of salary deferral arrangements. ... As a consequence thereof, the Plan should be amended to give the employee the right to withdraw funds only in the case of financial or other hardship. 3.      ...

In particular, you inquired concerning the following situations: 1.      ... Interest free loan made by a Canadian partnership to a related non-resident. 3.     Interest free loan made by a trust resident in Canada to a related non-resident. 4.      ...

30 May 1990 Ministerial Letter 900228 F- Internal Memorandum Unedited CRA Tags n/a   May 30, 1990 TORONTO DISTRICT OFFICE Business and General Appeals Division Division   Bill Guglich Dennis Jenkinson (613) 957-2102   File No. 900228 Subject: 19(1) This is in reply to your round trip memorandum dated March 21, 1990 concerning   24(1) We had the opportunity previously, to review a similar situation involving the case of  19(1). ...

19 March 1990 Ministerial Letter F3538 F- Annual Review of IC 78-5R2 Re Communal Organizations Unedited CRA Tags n/a   March 19, 1990 Enquiries and Taxpayer Current Amendments and Assistance Division Regulations Division   N.M. ... McNally 957-2079 Director   File No. F-3538 Annual Review of Inf. Cir. 78-5R2 Communal Organizations This is in reply to your memorandum of February 14, 1990 concerning the above. ...