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7 July 1991 Income Tax Severed Letter- Recovery of underdeducted non-resident tax — non-resident reinsurer Unedited CRA Tags 212(1)(b), 212(11) Subject: XXX This is in reply to your letter of April 10, 1991 concerning the review by the Non-Resident Unit in the Vancouver District Office of the XXX and the potential recovery of underdeducted non-resident tax. ...

7 May 1990 Income Tax Severed Letter RRRR394- Butterfly — allocation of liabilities Unedited CRA Tags 55(3)(b) Butterfly- Allocation of Liabilities Question Would the Department please provide its latest guidelines on the allocation of liabilities for purposes of a net equity method butterfly transaction. ...

7 December 1991 Income Tax Severed Letter- Foreign exchange — income or capital Unedited CRA Tags none XXX Principal issues Paragraph 1 of IT-95R outlines the major issue which must be addressed, that being, whether foreign exchange gains or losses are income or capital in nature. ...

10 December 1992 Income Tax Severed Letter 9212185- SR & ED Universities Approved Research Institute Unedited CRA Tags 37(1)(a) 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. ...

19 December 1985 Income Tax Severed Letter 5-8032- [] Unedited CRA Tags 67, 69, 212(1)(a), 212(3), 212(4) XXXX A.A. ...

26 July 1988 Income Tax Severed Letter 7-2888- [] Unedited CRA Tags 212(1)(o), 12.2, 56(1)(d.1), 115, 116 DATE July 26, 1988 TO Source Deductions Division Non-Resident Section Attention: E. ...

15 January 1986 Income Tax Severed Letter 5-0012- [] Unedited CRA Tags 21(1), 212(1)(b), 212(13), 216 XXXX C: Thornley (613) 995-2455 January 15, 1986 Dear Sirs: This is in reply to your letter dated November 5, 1985 concerning the interpretation of subsection 212(13)' of the Income Tax Act (the "Act") in the following situation: 1. ...

1 June 1991 Income Tax Severed Letter 91M06165 F- Canadian Exploration Expenses and Canadian Development | Expenses Unedited CRA Tags 66.1(6)(a), 66.2(5)(a), 66(12.62), 66(12.6), 66(10) Recommended Solution: 1)  Review of the Act: Canadian exploration expenses ("CEE") (defined in  paragraph 66.1(6)(a)) and Canadian development expenses ("CDE") (defined in paragraph 66.2(5)(a)) represent specific expenses incurred by a taxpayer.   ...

4 November 1982 Income Tax Severed Letter A-7163- [] XXXX S. Farber (613) 393-7295 November 4, 1982. ...

14 February 1989 Income Tax Severed Letter 7-3554-   TO Source Deductions Division L. ...