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You have asked us to make the following assumptions: 1.     Interest payable by the taxpayer to his spouse on the unpaid portion of the sale price is otherwise deductible by him in computing income. 2.     No election under subsection 73(1) of the Act has been made. 3.     Interest has not been paid on a timely basis. ...

2 October 1989 Ministerial Letter F3248 F- Capital Cost Allowance- Class 8 Property- Special Release to IT-472 Unedited CRA Tags n/a   October 2, 1989 Mr. ... Burnett 957-2078   File No. F-3248 Interpretation Bulletin Project Number 1685 Capital Cost Allowance- Class 8 Property Special Release to IT-472 We have reviewed the above draft project and have no comments with respect to policy matters, current or pending, that are relevant to positions taken in the draft. We do, however, have the following comments: 1)     Page 2- Subparagraph 1(iii)- reference "10(g) to (v)" should be "10(g) to (w)" and reference "34 or 37" should be "34, 37 or 39". 2)     Page 3- Paragraph (d)- The grandfathering provision only applies to property used to earn rental income. ...

This exception is an administrative concession by the Department and will not be available unless all of the six conditions set out by the Department, as restated hereunder, are satisfied. 1)     The corporation's only objective is the holding of property for the personal use or enjoyment of the shareholder. 2)     The shares of the corporation are held be an individual or person (other than a corporation) related to the individual. 3)     The only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. 4)     The shareholder would be charged with all the operating expenses by the corporation, with the result that the corporation would show no profit or loss with respect to the property on any of its returns. 5)     The corporation acquired the property with funds provided solely by the shareholder and not by virtue of his holdings or that of a related person in any other corporation. 6)     The property must be acquired by the corporation on a fully taxable basis (that is, without the use of any of the rollover provisions of the Act). ...

Adjusted cost base and paid-up capital have the meanings assigned by paragraphs 54(a) end 89(1)(c) of the Act, respectively. 2.      ... A's 9% interest in 0pco. 3.     Mr. A has used, or is unable to utilize, his capital gains exemption to reduce the tax on the sale of his 0pco shares.  ... A on a sale of the Opco shares would be, approximately, $334 (50% x 75% x (900-9)). 4.      ...

13 December 1989 Ministerial Letter ACF3398 F- CCA for Multiple-unit Residential Building- Revision of IT-367R2 Unedited CRA Tags n/a   December 13, 1989 Mr. ... Burnett- 957-2078   F-3398 Interpretation Bulletin Project Number 1617 Capital Cost Allowance- Multiple-Unit Residential Building Revision of IT-367R2 We have reviewed the above draft project and have the following policy concern relevant to positions taken in the draft: 21(1)(b) B.J. ...

10 November 1989 Ministerial Letter 89M11548 F- 1990 Federal Budget Unedited CRA Tags n/a   November 10, 1989 Mr. ... BrysonActing Director Current Amendments and Regulations Division Attachment c.c.      ...

3 January 1990 Ministerial Letter 90M01028 F- Unemployment Insurance (Collection of Premiums) Unedited CRA Tags n/a   January 3, 1990 Head Office Library Current Amendments and Acquisitions Unit Regulations Division Room 900, Metcalfe Building   File No. 90M01028 Unemployment Insurance (Collection of Premiums) Regulations Enclosed are an English and French version of the above Regulations that were passed by Order in Council P.C. 1989-2525 dated December 21, 1989. ...

.- 1990 Instalment Guide for Corporations Unedited CRA Tags n/a   November 6, 1989 TO- A. Bissonnette FROM- Technical Director Interpretations Division Revenue Programs Division Bernhard Buetow   957-9227 SUBJECT:  T7B- CORPORATIONS 1990 INSTALMENT GUIDE The Guide has been reviewed and as agreed per telephone with Marv. ...

1 June 1990 Ministerial Letter ACC9178 F- Butterfly Transactions- Dividend Treatment in the Case of an Arm's Length Disposition Unedited CRA Tags 55(2), 55(3)(b), 55(5)(e), 55(3)(a), 248(10), 55(4) Fact Situation II The facts are the same as in Fact Situation I except that: (a)     A had transferred the building to X Co at the beginning; and (b)     there was no corporate-owned insurance and no buy-sell agreement in place at his death. ...

Gillman Énergie, Mines & Ressources Canada 957-9768 Pièce 706, 580 rue Booth Ottawa, Ontario K1A 0E4 Attention:  M. ... Directeur général intérimaire Direction des décisionsDirection générale des affaireslégislatives & intergouvernementales ...