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In this regard, the relevant facts and information could include the following with respect to such a determination: (a)     the type of property acquired; (b) the use to which the property was put when the Taxpayer did not inhabit it; (c) the extent that the property is used by relatives and other individuals; and (d) whether rental income has been received. ...

13 June 1991 Internal T.I. 9110307 F- Meaning of "Benevolent or Fraternal Benefit Society or Order" Unedited CRA Tags 149(1), 149(3) 7-911030 24(1) This is in reply to your memorandum of April 15, 1991, concerning the tax status of the  24(1) under subsections 149(1) & (3) of the Act. ...

Kotlar 957-8962 Director   File No. 7-4719 Subject: Treatment of Additional Employer contribution on  Termination of a Money Purchase Pension Plan Your File- ITR 39868 This is in reply to your memorandum of February 8, 1990 prepared by M. ...

ClarkChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate Attachment c.c.:  W. ...

Humenuk   (613) 957-2135 Attention:  Richard Bergeron February 8, 1990 Dear Sirs: Re:  Proposed Settlement for Lost Salary We are responding to your letter of December 14, 1989, concerning a 24(1) In our conversation of February 4, 1990, with Mr. ...

That definition, contained in proposed section 2, reads as follows:     "subordinated indebtedness" means an instrument evidencing an indebtedness of a company that by its terms provides that the indebtedness will, in the event of the insolvency or winding-up of the company, be subordinate in right of payment to all policy liabilities of the company and all other liabilities of the company except those other liabilities that, by their terms, rank equally with or are subordinate to such indebtedness;". ...

27 July 1989 Internal T.I. 58317- Résidence à logements multiples Unedited CRA Tags 31, 32 19(1) File No. 5-8317   A.M. ...

2 December 1991 Internal T.I. 9125777 F- Legal Fees to Defend Alimony Quantum Unedited CRA Tags 18(1)(a), 56(1)(b), 18(1)(b)   912577 Legal Fees Incurred to Defend Right to Alimony This is in reply to your fax communication of August 30, 1991, relating to the deductibility of legal fees.                       24(1) You have asked for clarification as to whether the legal fees incurred to protect the right to alimony from a possible reduction in quantum is deductible in the same manner as legal fees incurred to enforce the payment of alimony or maintenance which has been included in income under paragraph 56(1)(b), (c) or (c.1) of the Income Tax Act (the Act).  ...

7 May 1992 Internal T.I. 9213647 F- Witholding Tax- Computer Software Royalties Unedited CRA Tags 212(1)(d)(i), 212(1)(d)(vi)   O.Laurikainen May 7, 1992 MONTREAL D.O.- CICA CONFERENCE Question 21(c) As a result of the passage on June 8, 1988 of Bill C-60, An Act to Amend the Copyright Act which amended the Copyright Act to include computer programs in the definition of "literary work" and the Supreme Court of Canada decision in Apple Computer Inc. v. ...

2 December 1991 Internal T.I. 9124317 F- RRSP- Qualified Investments Unedited CRA Tags 4900(1)(f)   7-912431 24(1)                               Dear Sir or Madam: This is in reply to your letter of July 10, 199l concerning qualified investments for a registered retirement savings plan ("RRSP"). ...