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18 January 1990 Ministerial Letter 59278 F- Qualified Investments for a Registered Retirement Plan Unedited CRA Tags n/a 19(1) File No. 5-9278   D. Duff   (613) 957-3498 January 18, 1990 Dear Sirs: Re:  Qualified Investments for a Registered Retirements Savings Plan This is in reply to your letter of December 15, 1989 wherein you requested a clarification of our administrative position regarding the requirements necessary for a non-arm's length participating mortgage to be a qualified investment for a Registered Retirement Savings Plan (RRSP).  ...

11 July 1990 Ministerial Letter 900718 F- Special Benefit Payment to Terminally Ill Policyholders Unedited CRA Tags 148(9) disposition 19(1) 900718   M.M. Trotier   (613) 957-8957 July 11, 1990 EACC9442 19(1) This is in reply to your letter of May 4, 1990 concerning the taxation of special benefit payments to policyholders suffering from a terminal illness made out of their existing life insurance policies. ...

21 November 1990 Ministerial Letter 902688 F- Non-Resident Withholding Tax on Distribution of Profits Unedited CRA Tags n/a 24(1) 902688   K.B. Harding   (613) 957-2130 19(1) November 21, 1990 Dear Sirs: This is in reply to your letter of September 24, 1990 wherein you requested our opinion with respect to the following hypothetical situation: Company A is a foreign corporation which makes substantial purchases from a Canadian exporter. ...

Income Tax Convention- Distribution of Partnership Assets Unedited CRA Tags n/a 19(1) File No. 5-8738   K.B. Harding   (613) 957-2129 January 24, 1990 Dear Sirs: This is in reply to your letter of September 1, 1989 wherein you requested our opinion concerning paragraph 8 of Article XIII of the Canada-U.S. ...

1 September 1989 Ministerial Letter 58308 F- Non-profit Organization Status Unedited CRA Tags 149(1)(l), 149(1)(j) 19(1) File No. 5-8308   C. Tremblay   (613) 957-2095 September 1, 1989 Dear Sirs: Re:  Non-Profit Organization Status This is in reply to your letter of May 15, 1989, and subsequent telephone conversations of July 24, and 25, 1989, 19(1) (Tremblay) concerning a contemplated course of action which may affect the non-profit status of a corporation. ...

20 December 1989 Ministerial Letter 58918 F- Treatment of Proceeds from a Life Insurance Policy Unedited CRA Tags n/a 19(1) 5-8918   K.B. Harding   (613) 957-2129 December 20, 1989 19(1) This is in reply to your letter of October 5, 1989 wherein you requested our views on the treatment of proceeds from a life insurance policy when received by residents and non-residents of Canada. 24(1) Resident of Canada A resident of Canada is required to include in income for the calendar year in respect of the disposition of an interest in a life insurance policy the amount, if any, by which the proceeds of disposition received in the year exceed the adjusted cost basis of the policyholder.  ...

5 April 1990 Ministerial Letter 59578 F- Income Tax Filing of a Missing Person Unedited CRA Tags n/a 19(1) File No. 5-9578   J.D. Jones   (613) 957-2104 April 5, 1990 Dear Sirs: Re:  Income Tax Filing of a Missing Person This is in reply to your letter of February 8, 1990, wherein you requested our opinion with respect to an interpretation of the income tax filing requirements of a missing person in the following situation. 24(1) Based upon the above, you have asked on what basis does the committee file Mr. ...

22 October 1989 Ministerial Letter 54868 F- Qualified Investments for RRSPs Unedited CRA Tags 4900, 5103, 5100 19(1) File No. 5-8468   F. Francis   (613) 957-3496 September 22, 1989 Dear Sirs: This is in reply to your letter of August 2, 1989 wherein you requested our opinion as to whether the shares of 24(1) would be qualified investments for registered retirement savings plans ("RRSP"). ...

27 March 1990 Ministerial Letter 59128 F- Capital Gains Exemption- Gains Allocation by Partnership Unedited CRA Tags 110.6, 39(5), 39(4), 96(3), 39(6) 19(1) File No. 5-9128   C.R. ... Our understanding of the facts given to illustrate the issue is as follows: 24(1) Your Questions 1.      ... Our Comments While we are unable to confirm, the income tax effects of the particular situation outlined in your letter, we can provide the following general comments related to the application of subsections 39(4), 39(5) and 110.6(2.1) of the Act. 1.      ...

The situations are set out below: 1.     Another party plants and harvests the crops and gives the taxpayer land owner a share of the crop instead of a fixed rent. 2.      ... Instead of paying the custom operator a fixed fee, the custom operator receives a percentage of crop. 3.      ... Each taxpayer pays for 1/2 of the inputs and receives 1/2 of the crop. 4.      ...