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7 March 1991 Income Tax Severed Letter- Accumulated vacation leave — whether considered retiring allowance Unedited CRA Tags 248(1) Dear Sir: Re: Accumulated Vacation Leave Whether considered Retiring Allowance This is in reply to your letter of November 20, 1990 concerning the above-mentioned subject. ...

7 November 1991 Income Tax Severed Letter- Amortization of pension surplus — income tax treatment to employer Unedited CRA Tags 20(1)(q), 56(1)(a)(i), 147.2(1), 248(1) Subject: Amortization of Pension Surplus Income Tax Treatment to Employer This is in reply to your memorandum of October 24, 1991 concerning the income tax implications where an employer amortizes for accounting purposes, but not for income tax purposes, an actuarial surplus in its pension plan. ...

7 September 1991 Income Tax Severed Letter- Deferral of payment — separation benefits Unedited CRA Tags none Subject: Deferral of Payment- Separation Benefits This is with respect to your memorandum of September 13, 1991 concerning the tax consequences to a retiring employee who requests the deferral of part of a lump sum payment until the following year in order to minimize income taxes. ...

7 June 1991 Income Tax Severed Letter- Large corporations tax — amounts received by a vendor corporation under a take-or-pay gas purchase contract Unedited CRA Tags 181.2 1991 CPTS ROUNDTABLE QUESTION 14. ...

7 July 1991 Income Tax Severed Letter- Life expectancy tables — joint and last survivor Unedited CRA Tags Reg. 300(2) Dear Sirs: Re: Life Expectancy Tables- Joint and Last Survivor This is in reply to your correspondence concerning life expectancy tables sent by facsimile transmission July 8, 1991. ...

7 October 1991 Income Tax Severed Letter- Capital gains exemption — prescribed share status on amalgamation Unedited CRA Tags Reg. 6205(4)(c) Capital Gains Exemption- Prescribed Share Status on Amalgamation Assume that preferred shares are issued by Amalco on an amalgamation in exchange for preferred shares of a predecessor corporation. ...

7 November 1991 Income Tax Severed Letter- Qualified small business corporation shares — “Primarily” test Unedited CRA Tags 110.6(1) Qualified Small Business Corporation Shares- "Primarily" Test QUESTION Under the definition of a qualified small business corporation share in 110.6(1) of the Act, one of the requirements is that assets are used in an active business carried on "primarily" in Canada (subparagraph (c)(i) of the definition). ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plans — eligibility of a teacher to use August at the beginning of, or July at the end of, a semestered leave in qualifying for the six consecutive months criteria Unedited CRA Tags Reg. 6801(a)(i) Dear Sir: Re: Deferred Salary Leave Plans This is in reply to your letter of September 25, 1991, to the Kingston District Office of Revenue Canada Taxation, requesting information on the eligibility of a teacher to use August at the beginning of, or July at the end of, a semestered leave in qualifying for the six consecutive months criteria. ...

20 November 1980 Income Tax Severed Letter RRRR29- Foreign exchange gains and losses — IT-95 Unedited CRA Tags IT-95 This is in reply to your memorandum dated September 11, 1980 concerning suggested changes to IT-95. ...

12 November 1980 Income Tax Severed Letter RRRR28- Section 15(2)(b) of the Teachers' Superannuation Act — non-resident tax exemption Unedited CRA Tags 212(1)(b) Dear Sirs: This is in response to your letter of October 28 concerning a specific section of the XXX Superannuation Act. ...