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7 August 1990 Income Tax Severed Letter- Interpretation of the phrase “ actively engaged” in the definition of the term ”share of the capital stock of a family farm corporation” in paragraph 70(10)(b) Unedited CRA Tags 70(10)(b) Dear Sirs: This is in reply to your letter of July 23, 1990 concerning the definition in paragraph 70(10)(b) of the term “share of the capital stock of a family farm corporation”. ...

7 March 1991 Income Tax Severed Letter- Retirement compensation arrangement — letter of credit Unedited CRA Tags none Dear Sirs: Re: Retirement Compensation Arrangement ("RCA") Letter of Credit This is in reply to your letter of January 22, 1991, concerning the above-mentioned subject matter. ...

7 March 1991 Income Tax Severed Letter- Income vs. capital gains — Canada-United Kingdom Income Tax Convention Unedited CRA Tags Canada–U.K. ...

7 August 1990 Income Tax Severed Letter- Comments about proposed T4079 — 1990 Reporting Guide for Amounts Paid out of RRSPs and RRIFs Unedited CRA Tags none T4079 1990 Reporting Guide for Amounts Paid out of RRSPs and RRIFs We are attaching the final circulation folder for the above-noted guide with the T84 signed-off. ...

7 November 1990 Income Tax Severed Letter- Depreciable property — allocation of proceeds on death Unedited CRA Tags 70(5)(b) QUESTION I-99 DEPRECIABLE PROPERTY- ALLOCATION OF PROCEEDS ON DEATH Assume a taxpayer dies owning several assets of the same class of depreciable property. ...

7 March 1991 Income Tax Severed Letter- Retention of ticket stubs — retention of records Unedited CRA Tags 230(4) Subject: Application of 230(4)- Retention of Ticket Stubs Further to our telephone conversation of February 25, 1991, we are forwarding the January 9, 1991, letter from XXX your consideration and reply. ...

7 June 1991 Income Tax Severed Letter- Income attribution — non-income producing property such as vacant land Unedited CRA Tags 74.4, 74.5 TAX EXECUTIVES INSTITUTE- VANCOUVER INCOME ATTRIBUTION QUESTION Will Section 74.4 of the Income Tax Act (the "Act") apply where non- income producing property, such as vacant land, is transferred to a corporation of which family members of the transferor are shareholders? ...

7 November 1990 Income Tax Severed Letter- Partnership — negative adjusted cost base Unedited CRA Tags 98 QUESTION #41- PARTNERSHIP- NEGATIVE ADJUSTED COST BASE Where subsection 98(6) applies to a continuation of a Canadian partnership by a new partnership and the interest of a partner in the predecessor partnership has a negative adjusted cost base at the end of a fiscal period of the partnership, do the deeming provisions of subsection 98(1)(c), which would otherwise deem the negative adjusted cost base of the partner's interest in the partnership to be a gain of the partner from a disposition of the interest? ...

7 October 1990 Income Tax Severed Letter- Deferred profit sharing plan — registered retirement savings plan Unedited CRA Tags 147(2)(i.1), 146(5) Dear Sirs: Re: Paragraph 147(2)(i.1) of the Income Tax Act (the "Act")- Deferred Profit Sharing Plan ("DPSP")- Registered Retirement Savings Plan ("RRSP") This is in reply to your letter of September 5, 1990 wherein you request a technical interpretation concerning the application of subsection 146(5) to the 1990 calendar year. ...

25 March 1981 Income Tax Severed Letter RRRR40- Non-resident withholding tax exemption — lease and option agreements Unedited CRA Tags 212(1)(b)(vii) XXX Re: Paragraph 212(1)(b)(vii) Lease- Option Agreements Thank you for your letter of February concerning the application of paragraph 212(1)(b)(vii) of the Act to 'financial leases'. ...