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7 September 1990 Income Tax Severed Letter- Foreign affiliates — deduction available under subparagraph 91(5)(b)(i) Unedited CRA Tags 91(5)(b)(i), 91(1), 92(1)(a), 95(1)(b)(k), Reg. 5901(2) Dear Sirs: Re: Subparagraph 91(5)(b)(i) of the Income Tax Act (the "Act") This is in response to your letter of March 1, 1990. ...

7 September 1990 Income Tax Severed Letter- Self-funded leave plan and the Canada Pension Plan — followup letter Unedited CRA Tags none Dear Mr. ...

31 October 1980 Income Tax Severed Letter RRRR24- Interpretation of subparagraph 212(1)(b)(vii) — non-resident tax withholding exemption Unedited CRA Tags 212(1)(b)(vii) Dear Sir: This is in reply to your letter of October 24, 1980 concerning the interpretation of subparagraph 212(1)(b)(vii). ...

4 February 1981 Income Tax Severed Letter RRR21- Tax implications where shares of a private taxable Canadian corporation are sold — Canada-Australia Income Tax Convention Unedited CRA Tags 2(3), 115(1)(b), 212(2) 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. ...

4 November 1980 Income Tax Severed Letter RRRR27- Non-resident withholding tax — transfer from RPP or DPSP to another RPP, RRSP,or to purchase IAAC when member is non-resident of Canada Unedited CRA Tags 61, 212(1), 212(1)(h), 212(1)(m), 214(3)(d) Dear Sirs: This is in response to your letter of October 3 concerning the appropriateness of Part XIII withholding tax when amounts are transferred from an R.P.P. or a D.P.S.P. to another R.P.P., an R.R.S.P. or to purchase an I.A.A.C. when the member of these plans is a non-resident of Canada. ...

7 July 1990 Income Tax Severed Letter- Low interest loans — deemed benefit calculation under section 80.4 of the Income Tax Act Unedited CRA Tags 80.4 Dear Sirs: Re: Low Interest Loans We are replying to your letter of April 9, 1990, concerning the exceptions to the deemed benefit calculation under section 80.4 of the Income Tax Act. ...

3 May 1990 Income Tax Severed Letter RRRR276 F- Réduction du montant de l'impôt des non-résidents à retenir — paragraphes 215(5), 120.2(1), 120.2(4) de la Loi de l'impôt sur le revenu Unedited CRA Tags 215(5), 120.2(1), 120.2(4) 5- 9375 A. ...

22 June 1992 Income Tax Severed Letter- Taxation of employment income received by Indians — Special Interchange Canada Program Unedited CRA Tags 81(1) 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. ...

30 May 1990 Income Tax Severed Letter RRRR284- Taxable benefits — sale of merchandise to employees at less than employer's cost Unedited CRA Tags 6(1)(a) 5- 9721 J.D. ...

7 May 1991 Income Tax Severed Letter- Deemed dividend — reorganization of capital Unedited CRA Tags 84(1), 86, 89(1)(c) BRITISH COLUMBIA TAX STUDY GROUPS ROUND TABLE- 1991 Question 13: Deemed Dividend- Reorganization of Capital Does subsection 84(1) deem a dividend to be paid and received where a corporation issues no-par-value shares (the "new shares") in exchange for previously issued shares of a different class (the "old shares") in the course of a section 86 reorganization of capital in circumstances where the fair market value of the new shares exceeds the paid-up capital of the old shares? ...