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2 September 1980 Income Tax Severed Letter RRRR19- Certificate of Exemption — NR602A Unedited CRA Tags 212(1)(b)(iv), 212(14) Dear XXX This is in response to your letter of June 2 dealing with a withholding tax exemption by the XXX when purchasing Canadian commercial paper. ...

7 April 1991 Income Tax Severed Letter- Employee profit sharing plan — non-resident employees Unedited CRA Tags none Dear Sirs: Re: Employee Profit Sharing Plan ("EPSP") Non-Resident Employees This is in reply to your letter of March 28, 1991 concerning the above- referenced matter. ...

7 September 1991 Income Tax Severed Letter- Taxable Canadian property — shares in a public corporation Unedited CRA Tags 115 Taxable Canadian Property- Shares in a Public Corporation Question Subparagraph 115(1)(b)(iv) defines taxable Canadian property to include a share of the capital stock of a public corporation if at any time during the prescribed five-year period not less than 25% of the issued shares of any class belonged to the non-resident person, non-arm's length persons or a combination of the foregoing. ...

7 November 1990 Income Tax Severed Letter- Acquisition of control — recognition of unrealized foreign exchange gains and losses Unedited CRA Tags 111(4), 248(1) QUESTION I 88 Acquisition of Control- Recognition of Unrealized Foreign Exchange Gains and Losses Control of a corporation is acquired at a time when it has an unrealized capital loss on preferred shares of a foreign affiliate. ...

12 January 1981 Income Tax Severed Letter RRRR31- Application of paragraph 212(13)(f) — non-resident withholding tax exemption on personal loan Unedited CRA Tags 212(13)(f) This is in reply to your Round Trip Memorandum dated December 24, 1980 requesting our opinion as to the application of paragraph 212(13)(f) to the following situation. ...

7 October 1991 Income Tax Severed Letter- Status Indians — tax treatment of interest earned on a reserve Unedited CRA Tags none Dear Sirs: Re: Status Indians-Interest Earned on a Reserve This is in reply to your letter of September 11, 1991 advising that the XXX You ask that we confirm the position in Interpretation Bulletin IT-62 that states, "Interest on a bank account is earned at the location at which the funds are on deposit, i.e. the specific bank branch address". ...

7 September 1991 Income Tax Severed Letter- Loan to non-resident — meaning of “reasonable rate” Unedited CRA Tags 17 Loan to Non-Resident- What is "Reasonable Rate" Question What is Revenue Canada's position concerning a reasonable rate of interest for purposes of subsection 17(1) on a loan denominated n foreign currency to a wholly-owned foreign subsidiary where the exceptions in subsections 17(2) and 17(3) do not apply. ...

8 July 1980 Income Tax Severed Letter RRRR12- Foreign affiliates — subsection 93(1) election Unedited CRA Tags 93(1) XXX This is in response to your memorandum of February 13, 1980, concerning the late filing of an election under subsection 93(1) of the Income Tax Act before the provision for late filing pursuant to subsection, 93(5) of the Act became effective on December 6, 1979. ...

7 December 1991 Income Tax Severed Letter- Deferred income plans — foreign currency Unedited CRA Tags 259(1)(b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plan — minimum period of leave Unedited CRA Tags Reg. 6801 Dear Sirs: Re: Deferred Salary Leave Plans We are writing in reply to your letter of October 3, 1991, concerning the requirements that a deferred salary leave plan provide for a minimum six consecutive months leave of absence. ...