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Lee Workman Manager Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

The put option also stipulates that the Taxpayer will not be required to accept put options for more than XXXXXXXXXX % of the units from all producers in any one year, to be determined on a FIFO basis. e) Clause XXXXXXXXXX of the Agreement states: "...XXXXXXXXXX... ...

John Oulton Manager Business, Property & Employment Section III Business and Publications Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

John Oulton Section Chief Business, Property & Employment Section III Business and Publications Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

. * re-employment with the employer (on a full or part-time basis)... pursuant to an arrangement made prior to the termination of employment. ...

John Oulton Manager Business, Property & Employment Section III Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch?? ...

Principal Issues: Does the particular individual get a deduction pursuant to paragraph 110(1)(d) on his stock option benefit Position: no Reasons: Because he purchases shares at a XXXXXXXXXX % discount from the lower of FMValues of the shares at the beginning or end of a six-month period, he does not meet the criteria in subparagraph 110(1)(d)(ii) July 4, 2000 Edmonton TSO HEADQUARTERS Business and Enquiries Area Mary Pat Baldwin 957-2087 Attention: Ms. ...

June 19, 2000 INDIVIDUAL RETURNS & PAYMENTS HEADQUARTERS PROCESSING DIRECTORATE M.P. ...

DOCUMENT TYPE: CCRA Documents; (Forms & Guides, Internal Queries, Appeals Referrals) Principal Issues: Calculation of refund interest and instalment interest when overpayment transferred to another taxpayer's instalment account Position: Overpayment and accumulated refund interest transferred effective on date of notice of assessment or reassessment. ...

A) Canco incorporates and capitalises a 100 % owned controlled foreign affiliate ("CFA") after 1995. ...