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25 July 1990 Ministerial Letter 74608 F- Minimum Tax Carry Over and Non-residents Unedited CRA Tags n/a   July 25, 1990 Non-Resident Taxation Division Rulings Directorate   M.P. ... Hillier 957-2125 Director   7-4608 SUBJECT: Minimum Tax Carry-Over and Non-Residents File HDB 8788-1 This is in reply to your memorandum of December 20, 1989 regarding the application of the minimum tax carry-over provisions to reduce Part I tax pertaining to a non-resident. ...

12 January 1990 Ministerial Letter 74378 F- Settlement Payment Unedited CRA Tags 5(1), 6(3)   January 12, 1990 Assessing and Enquiries Directorate Business and General P. ... Humenuk Division 957-2135 Norm O'Donnell   File No. 7-4378   Your File: HAV 5804-2 Subject: 24(1) We are replying to your memorandum received September 29, 1989, concerning the characterization of a payment made in settlement of a claim against the above noted employer. ...

16 October 1989 Ministerial Letter 74318 F- Whether Lump-sum Payment Constitutes Retiring Allowance Unedited CRA Tags 248(1) retiring allowance   October 16, 1989 To SAINT JOHN, N.B. DISTRICT OFFICE  HEAD OFFICE Enquiries & Office Examination Financial Industries Division   Maureen Shea-DesRosierss Attention:  Anne Blanchard (613) 957-8953 Subject:  Whether Lump-Sum Payment constitutes Retiring Allowance This is in reply to your memorandum of September 7, 1989 with attached T2020 and a copy of the 24(1) You describe the facts as follows: 24(1) The question raised was whether the payment of 24(1) to each employee was retiring allowance. ...

Facts 1.     Holdco, a Canadian-controlled private corporation, is wholly owned by Mr. ... Opco, a Canadian-controlled private corporation, is wholly owned by Holdco. 3.     The above outlined corporate share ownership has remained unchanged for over 24 months. 4.      ...

Osborn   (613) 957-2120 19(1) June 29, 1990 Dear Sirs: Re:  Subsection 55(2) of the Income Tax Act (the "Act") We are writing in response to your letter of February 19, 1990. You requested our comments regarding the application of subsection 55(2) of the Act in the following hypothetical circumstances. (1)     Opco is a Canadian-controlled private corporation and  a taxable Canadian corporation within the meanings of paragraphs 125(7)(b) and 89(1)(i) of the Act, respectively. (2)     The common shareholders of Opco are married individuals owning 65 per cent and 35 per cent of the issued shares respectively. (3)     The corporation has a fair market value of $1,000,000 represented by $800,000 of active business assets and $200,000 cash. (4)     The corporation has accumulated $500,000 in safe income for the purposes of subsection 55(2) of the Act. (5)     The shareholders intend to sell 50 per cent of each of their shareholdings to an arm's length party for $500,000. (6)     Before the intended sale, a new company ("Newco") is incorporated, and the spouses transfer one half of their respective shares of Opco to Newco pursuant to the provisions of subsection 85(1) of the Act and receive common shares of Newco as consideration.  The agreed amount under paragraph 85(1)(a) of the Act will equal the adjusted cost base, as defined under paragraph 54(a) of the Act, of the Opco shares. (7)     The common shares of Opco owned by Newco are then exchanged, under the provisions of section 86 of the Act, for Voting, redeemable, retractable preference shares having an aggregate paid-up capital equal to the paid-up capital of the common shares exchanged. (8)     The preference shares will be redeemable at an amount of $500,000 less any dividends paid on them before redemption. (9)     Opco then declares a $200,000 dividend on the preferred shares. ...

25 September 1989 Ministerial Letter 58508 F- Deferred Salary Leave Plan for Teachers Unedited CRA Tags 6801(a) 19(1) File No. 5-8508   A.B. Adler   (613) 957-8962 September 25, 1989 Dear Sirs: This is in reply to your letter of August 4, 1989 in which you requested a technical interpretation concerning a proposed deferred salary leave plan ("Plan") for teachers. ... Our comments with respect to your Plan are as follows. 1.     Clause 3.2 of the Plan should make it clear that the maximum percentage deferral in any taxation year of a participant cannot exceed 33-1/3% of the amount of salary or wages that the participant would normally receive in that year (subparagraph 6801(a)(ii) of the Regulations). 2.      ...

19 September 1989 Ministerial Letter 58568 F- Deductibility of Brokers' Fees for the Management of RRSP Investments Unedited CRA Tags 20(1)(bb) 19(1) File No. 5-8568   Blair P. Dwyer   (613) 957-2744 September 19, 1989 Re:  Paragraph 20(1)(bb) of the Income Tax Act (Canada) (the "Act") This is in reply to your letter dated August 23, 1989, in which you asked for confirmation of earlier telephone advice concerning whether an annuitant under a RRSP may deduct administration fees charged by brokers for the management of RRSP investments. ...

9 August 1989 Ministerial Letter 58178 F- Term Life Insurance Premiums Deductibility Unedited CRA Tags 20(1)(e.1) 19(1) File No. 5-8178   Blair P. Dwyer   (613) 957-2744 August 9, 1989 19(1) Re:  Term Life Insurance Annual Premiums Deductibility under Paragraph 20(1)(e.1) of the Income Tax Act (Canada) (the "Act") This is in reply to your letter dated May 31, 1989, in which you requested our current views on whether annual premiums for term life insurance are deductible under paragraph 20(1)(1)(e) or (e.1) of the Act. ...

26 July 1990 Ministerial Letter 901558 F- Native Business Interpretation Unedited CRA Tags n/a 24(1) 901558   Glen Thornley   (613) 957-2101 Attention: 19(1) EACC9388 July 26, 1990 Dear Sirs: Re:  Native Business Interpretation This is in reply to your letter of June 25, 1990 requesting clarification with respect to certain activities 24(1) undertaking with status Indians. ... Having stated the foregoing as background information, your questions will be answered in the order raised. a)     Interest earned and credited on a deposit maintained at the 24(1) where the status Indian physically attends that branch and is a member of the 24(1)     band is received as exempt income pursuant to paragraph 6(iv) of IT-62. b)     Interest earned and credited on a deposit maintained at the 24(1) where the status Indian uses the automated teller system (and does not physically attend the branch) and is a member of the 24(1) band is received as exempt income as in (a) above. c)     Interest earned and credited on a deposit maintained at the 24(1) where the status Indian physically attends that branch but is not a member of the 24(1)     band is received as exempt income as in (a) above. d)     Interest earned and credited on a deposit maintained at the 24(1) where the status Indian uses the automated teller system (and does not physically attend the branch) and is not a member of the 24(1) band is received as exempt income as in (a) above. e)     Interest earned on guaranteed investment certificates offered by the 24(1) is considered taxable in the hands of a status Indian as the situs of the payer is off the reserve.  The situs of the payer in this case would be the Head Office of the 24(1) which presumably is not on a reserve anywhere. f)     Interest earned on Canadian government Treasury Bills is considered taxable in the hands of status Indians as the situs of the payer, the Government of Canada, is off the reserve. g)     Interest earned and withdrawn from an RRSP is taxable in the hands of a status Indian as RRSP's are trusted and from information received, we understand that the trustees are generally situated in a Head Office location which is not on a reserve.  ...

18 January 1990 Ministerial Letter 74598 F- Support and Custody Agreement Unedited CRA Tags 60(b), 60(c), 60(c.1), 56(1)(c.1)   January 18, 1990 ST. CATHARINES DISTRICT OFFICE Specialty Rulings   Directorate D. Doney J.D. ... Roy10th Floor123 Slater Street c.c.     Provincial and InternationalRelations Division ...